https://www.taxtmi.com/caselaws?id=441167 Royalty under Article 12 of the India-UAE DTAA was taxable only on actual receipt of consideration, not on a notional or deemed basis. In a dry lease of a helicopter, the lease rental could not be brought to tax where the parties were in dispute and no payment was actually received during the relevant year, even though invoices were raised and tax was reflected in Form 26AS. On that factual footing, the proposed addition was unsustainable and was deleted for the year under consideration. en-us Mon, 31 Jul 2023 00:00:00 +0530 Thu, 03 Aug 2023 07:54:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441167 Royalty under Article 12 of the India-UAE DTAA was taxable only on actual receipt of consideration, not on a notional or deemed basis. In a dry lease of a helicopter, the lease rental could not be brought to tax where the parties were in dispute and no payment was actually received during the relevant year, even though invoices were raised and tax was reflected in Form 26AS. On that factual footing, the proposed addition was unsustainable and was deleted for the year under consideration. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441167