5. As used in this section, the term “dividends” refers to income from shares or other non-profit rights, as well as income from other rights of corporations treated as proceeds of shares by the tax laws of the contracting state whose distribution is distributed, and anything other than interests covered by section 12, which is considered a dividend or distribution under the Act. (iv) British Airways has a branch in India that has established a stable establishment (“EP”) in India and, as a result, the income from the stable establishment in India was taxable, the same non-double taxation prevention. 3. For the purposes of this article, “aircraft operation” means the air transport of persons, live animals, goods or mail by aircraft owners, tenants or charterers, including the sale of air tickets for that transportation on behalf of other activities directly related to that transportation.” These conditions are not included in the two double taxation agreements of this appeal. (v) Article 8, paragraph 2 of the Convention on the Prevention of Double Taxation between India and the United Kingdom provides that Article 8, paragraph 1, also applies to participation in pools of any kind. The terms “pools of all kinds” were interpreted by the Court of Appeal for Income Tax under the dictionary of the term “pool.” These are lacking in the two conventions at issue to avoid double taxation. In light of the above, this court considers that the strengthening of the concept of “aircraft operation” in Article 8, paragraph 1, by Article 8, paragraph 3, that is, the strengthening of the concept of “aircraft operation” by Article 8, paragraph 3, that is, 3. , carried out by aircraft owners, takers or charterers, including the sale of air tickets for this transport on behalf of another company, ancillary rental or chartered aircraft and any other activity directly related to such transport …
Limit the nature of activities that could be included in the Pool of Article 8, paragraph 2; In other words, the increased importance of aircraft operations included these activities in section 8, paragraph 3, by the expanded definition, rather than. On the other hand, there are no such restrictions in the conventions in question to avoid double taxation in these cases.