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Non-resident engaged in the business of operation of aircraft - Notwithstanding contrary provision in Section 28 to 43A
5% of the sum total of : -
Amount paid or payable (whether in or out of India) to the assessee, or to any person on his behalf ,on account of the carnage of goods, passengers, livestock, mail from any place in India ; and
Amount received or deemed to be received in India by or on behalf of the assessee on account of the carriage of passengers, livestock, mail or goods from any place outside India.