https://www.taxtmi.com/caselaws?id=360244 Payments under separate technical support and crew lease arrangements to a foreign airline required fresh examination to determine whether they constituted fees for technical services under the Indo-German DTAA and the Income-tax Act. The approved aircraft lease agreement was treated as distinct from the unapproved support and crew lease agreements, and the earlier appellate reasoning was found insufficient because it relied on an advance ruling in a different treaty context without analysing Article VIIIA or the interaction between section 9(1)(vii) and the treaty. The matter was remitted to the Tribunal for reconsideration on taxability under the treaty and the Act. en-us Tue, 08 May 2018 00:00:00 +0530 Fri, 08 Jun 2018 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360244 Payments under separate technical support and crew lease arrangements to a foreign airline required fresh examination to determine whether they constituted fees for technical services under the Indo-German DTAA and the Income-tax Act. The approved aircraft lease agreement was treated as distinct from the unapproved support and crew lease agreements, and the earlier appellate reasoning was found insufficient because it relied on an advance ruling in a different treaty context without analysing Article VIIIA or the interaction between section 9(1)(vii) and the treaty. The matter was remitted to the Tribunal for reconsideration on taxability under the treaty and the Act. Case-Laws Income Tax Tue, 08 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360244