The Mumbai Bench of the Income-tax Appellate Tribunal held that income derived from booking of seat/space under a code-sharing agreement is not to be treated as a space/slot charter absent a link between travel from India to interim destinations by third parties under a code-sharing agreement and from interim destinations to final destinations by the taxpayer’s owned/chartered/leased aircraft. Therefore, receipts from the code-sharing agreement do not qualify as profits derived from the operation of aircraft/ship in international traffic under provisions of the India-United States income tax treaty.  In this case, the third party contributed its aircraft and the taxpayer was only...