Section 1993(5)(f) in The Agreement Between the Government of India and Government of Afghanistan for avoidance of Double Taxation of income of enterprises operating aircraft.
(f)The term " operation of aircraft " means a business of transportation by air of persons, livestock, goods or mail carried on by the owners or lessors or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprises and any other activity directly connected with such transportation.