Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
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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.
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