https://www.taxtmi.com/caselaws?id=65050 Section 10(15A) is analysed as exempting aircraft-lease payments unless the lessor actually supplies spares or renders facilities or services connected with aircraft operation; reserve payments linked to the lessee's maintenance obligations are treated as outside that exclusion. The note also addresses simulator-based training as fee for technical services where technical knowledge is made available, repair and overhaul contracts as technical services when parts are incidental, and exchange of spare parts by segregating purchase elements from service charges. It further considers navigational data payments as potentially royalty-linked subject to treaty and PE review, and applies a reasonable-time limitation principle to section 201 orders, with a four-year benchmark for older years. en-us Tue, 12 Feb 2002 00:00:00 +0530 Wed, 24 Dec 2025 17:32:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65050 Section 10(15A) is analysed as exempting aircraft-lease payments unless the lessor actually supplies spares or renders facilities or services connected with aircraft operation; reserve payments linked to the lessee's maintenance obligations are treated as outside that exclusion. The note also addresses simulator-based training as fee for technical services where technical knowledge is made available, repair and overhaul contracts as technical services when parts are incidental, and exchange of spare parts by segregating purchase elements from service charges. It further considers navigational data payments as potentially royalty-linked subject to treaty and PE review, and applies a reasonable-time limitation principle to section 201 orders, with a four-year benchmark for older years. Case-Laws Income Tax Tue, 12 Feb 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65050