https://www.taxtmi.com/caselaws?id=775946 Aircraft lease documentation was read as an operating lease because the lessor retained ownership throughout, the lessee had to redeliver the aircraft at expiry, no term transferred title, and the contractual restrictions were consistent with a lease rather than a financing arrangement. The indicia of a finance lease were absent since ownership did not pass on expiry or on payment of any residual amount, and the lease term did not exhaust the aircraft's economic life. On that basis, the rentals were treated as rent and not interest under Article 11 of the India-Ireland DTAA, and the addition was deleted. en-us Fri, 25 Jul 2025 00:00:00 +0530 Tue, 07 Oct 2025 15:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775946 Aircraft lease documentation was read as an operating lease because the lessor retained ownership throughout, the lessee had to redeliver the aircraft at expiry, no term transferred title, and the contractual restrictions were consistent with a lease rather than a financing arrangement. The indicia of a finance lease were absent since ownership did not pass on expiry or on payment of any residual amount, and the lease term did not exhaust the aircraft's economic life. On that basis, the rentals were treated as rent and not interest under Article 11 of the India-Ireland DTAA, and the addition was deleted. Case-Laws Income Tax Fri, 25 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775946