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    <title>2005 (4) TMI 269 - ITAT DELHI-G</title>
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    <description>Supplemental lease rent paid to non-resident aircraft lessors remained outside the exclusion in section 10(15A) because the agreements did not show any supply of spares, facilities or services in return for those payments. The amounts were only reserve payments linked to maintenance and airworthiness costs, and the post-amendment wording was intended to tax only payments actually made for spares, facilities or services provided by the foreign enterprise. As the payments continued to qualify for the exemption, there was no obligation to deduct tax at source under section 195, and no default under section 201(1).</description>
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      <title>2005 (4) TMI 269 - ITAT DELHI-G</title>
      <link>https://www.taxtmi.com/caselaws?id=65435</link>
      <description>Supplemental lease rent paid to non-resident aircraft lessors remained outside the exclusion in section 10(15A) because the agreements did not show any supply of spares, facilities or services in return for those payments. The amounts were only reserve payments linked to maintenance and airworthiness costs, and the post-amendment wording was intended to tax only payments actually made for spares, facilities or services provided by the foreign enterprise. As the payments continued to qualify for the exemption, there was no obligation to deduct tax at source under section 195, and no default under section 201(1).</description>
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