https://www.taxtmi.com/caselaws?id=65050 Aircraft lease reserve payments linked to the lessee's maintenance and airworthiness obligations fall within the lease-payment exemption where the lessor does not itself supply spares, facilities or operational services; consequently, no tax deduction obligation arises on those payments. Simulator training and engine repair consideration may constitute fees for technical services, although grossed-up tax demands require recomputation where tax was not deducted. Repair-versus-purchase components in spare-parts exchanges require invoice-level segregation. Payments for navigational data/software require examination of royalty, treaty and permanent-establishment aspects. Treaty-scope issues concerning engine repairs may require further factual consideration. Orders imposing withholding-tax default consequences must be made within a reasonable time; four years from the end of the relevant assessment year was treated as reasonable, rendering the specified earlier-year order time-barred. 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 Aircraft lease reserve payments linked to the lessee's maintenance and airworthiness obligations fall within the lease-payment exemption where the lessor does not itself supply spares, facilities or operational services; consequently, no tax deduction obligation arises on those payments. Simulator training and engine repair consideration may constitute fees for technical services, although grossed-up tax demands require recomputation where tax was not deducted. Repair-versus-purchase components in spare-parts exchanges require invoice-level segregation. Payments for navigational data/software require examination of royalty, treaty and permanent-establishment aspects. Treaty-scope issues concerning engine repairs may require further factual consideration. Orders imposing withholding-tax default consequences must be made within a reasonable time; four years from the end of the relevant assessment year was treated as reasonable, rendering the specified earlier-year order time-barred. Case-Laws Income Tax Tue, 12 Feb 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65050