Section 1993(3) in The Agreement Between the Government of India and Government of Afghanistan for avoidance of Double Taxation of income of enterprises operating aircraft.
(3)The exemption provided for in paragraphs (1) and (2) above shall also apply in respect of participation in pools of any kind regarding air transport by the airlines of India or Afghanistan; the exemption shall not, however, apply to income from operation of aircraft in internal traffic in India or Afghanistan.