https://www.taxtmi.com/caselaws?id=302983 Fleet introductory assistance credits received under a separate engine agreement were treated as capital receipts because their character was fixed by the purpose of the payment at accrual; they were not taxable as business income, commission income, or capital gains, and did not fall within section 28(i) or 28(iv). Proportionate lease rentals were not disallowable under section 37(1) because no direct nexus was shown between the lease payments and the credits, and the lease structure was a later commercial arrangement. Supplementary lease rent was held to be allowable business expenditure; for pre-1 April 2007 leases it fell within the exemption regime, and for later leases treaty treatment prevented taxation in India, so disallowance under section 40(a)(i) was unwarranted. en-us Fri, 03 Sep 2021 00:00:00 +0530 Tue, 07 Oct 2025 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302983 Fleet introductory assistance credits received under a separate engine agreement were treated as capital receipts because their character was fixed by the purpose of the payment at accrual; they were not taxable as business income, commission income, or capital gains, and did not fall within section 28(i) or 28(iv). Proportionate lease rentals were not disallowable under section 37(1) because no direct nexus was shown between the lease payments and the credits, and the lease structure was a later commercial arrangement. Supplementary lease rent was held to be allowable business expenditure; for pre-1 April 2007 leases it fell within the exemption regime, and for later leases treaty treatment prevented taxation in India, so disallowance under section 40(a)(i) was unwarranted. Case-Laws Income Tax Fri, 03 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302983