Technical handling services, by airlines being member of IATP, from not taxable as per Article 8 of India-France DTAA

INCOME TAX : Where assessee company is a member of IATP and DTAA between India and France clearly set out that those who are members of pool are exempt from tax in India, Assessing Officer was not right in rejecting claim of assessee that profit from technical handling services was covered by Article 8 and in treating Technical Income as "fee for technical services" covered u/s 115A, read with Section 44D and taxed same at 20% of gross receipts

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