Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT affirmed that the assessee's income from aircraft leasing is not taxable in India under Article 8 of the India-Ireland DTAA, following the coordinate-bench precedent. The Tribunal held that interest on deferred lease payments, being charged for delayed lease rentals and directly connected to aircraft operations, constitutes an integral component of lease income and therefore falls within Article 8 rather than separate interest provisions. Consequently, benefits under the DTAA are not denied by the PPT/MLI in this context. The AO is directed to allow the assessee's claim that the impugned income is not chargeable to tax, to verify whether such interest was included in prior additions to leasing profits, and to give effect to this order.
ITAT affirmed that the assessee's income from aircraft leasing is not taxable in India under Article 8 of the India-Ireland DTAA, following the coordinate-bench precedent. The Tribunal held that interest on deferred lease payments, being charged for delayed lease rentals and directly connected to aircraft operations, constitutes an integral component of lease income and therefore falls within Article 8 rather than separate interest provisions. Consequently, benefits under the DTAA are not denied by the PPT/MLI in this context. The AO is directed to allow the assessee's claim that the impugned income is not chargeable to tax, to verify whether such interest was included in prior additions to leasing profits, and to give effect to this order.
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