https://www.taxtmi.com/caselaws?id=117481 Wet leasing of aircraft with crew and operational support was treated as leasing, not as the business of operating aircraft, so section 44BBA did not apply. The arrangement remained a lease because the airline operated the flights under its own banner and retained commercial responsibility for carriage. The receipts were also held to accrue in India through a business connection, so the entire lease consideration was taxable in India rather than only a proportionate part. Where no books or supporting particulars were produced, income could be estimated on a reasonable evidentiary basis, and the 29.7 per cent estimate was upheld as not arbitrary. en-us Tue, 21 Jun 2005 00:00:00 +0530 Fri, 22 Jun 2012 18:31:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=117481 Wet leasing of aircraft with crew and operational support was treated as leasing, not as the business of operating aircraft, so section 44BBA did not apply. The arrangement remained a lease because the airline operated the flights under its own banner and retained commercial responsibility for carriage. The receipts were also held to accrue in India through a business connection, so the entire lease consideration was taxable in India rather than only a proportionate part. Where no books or supporting particulars were produced, income could be estimated on a reasonable evidentiary basis, and the 29.7 per cent estimate was upheld as not arbitrary. Case-Laws Income Tax Tue, 21 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=117481