Assistant Director Of Income Tax (International Taxation) vs Delta Airlines Inc.

Whether income from security screening services and third party charter handling services provided to other airlines qualifies for exemption under Article 8 of the Indo-US DTAA as 'profits derived from operation of aircraft in international traffic' or 'other activity directly connected with such transportation' --- Held Yes, the assessee is entitled to exemption as these services are integral and ancillary to its main air transport operations.