Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
ITAT held that the lease agreements between the assessees (as lessors) and various aviation companies (as lessees) for leasing Airbus aircrafts are, in substance and form, operating leases. The Tribunal noted that the agreements are identical across all appeals and are pari materia with previously examined aircraft lease transactions, warranting consistent characterization. Consequently, income from such leasing is to be assessed as operating lease income and not as income from the operation of aircraft in international traffic. Further, following its earlier coordinate bench ruling on identical facts, ITAT denied the assessees' claim for benefit under Article 8 of the India-Ireland tax treaty and dismissed the assessees' appeals.
ITAT held that the lease agreements between the assessees (as lessors) and various aviation companies (as lessees) for leasing Airbus aircrafts are, in substance and form, operating leases. The Tribunal noted that the agreements are identical across all appeals and are pari materia with previously examined aircraft lease transactions, warranting consistent characterization. Consequently, income from such leasing is to be assessed as operating lease income and not as income from the operation of aircraft in international traffic. Further, following its earlier coordinate bench ruling on identical facts, ITAT denied the assessees' claim for benefit under Article 8 of the India-Ireland tax treaty and dismissed the assessees' appeals.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
