https://www.taxtmi.com/caselaws?id=780420 Aircraft leasing income from a dry lease to Indian airlines was treated as not taxable in India where the Irish lessors held valid tax residency certificates, carried on genuine business activity, and no sham, round-tripping, or dominant tax-avoidance purpose was shown. Treaty relief could not be denied merely by invoking the MLI Principal Purpose Test without domestic incorporation through notification under section 90(1), and the facts did not establish a fixed place permanent establishment because the aircraft were not at the lessors' disposal. Delayed payment or penal charges for lease rentals were also held not taxable, as they were not business income in the absence of a PE and were excluded from ordinary interest treatment under the treaty; relief was extended consistently with the exempt lease rentals. en-us Mon, 06 Oct 2025 00:00:00 +0530 Thu, 30 Oct 2025 08:22:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780420 Aircraft leasing income from a dry lease to Indian airlines was treated as not taxable in India where the Irish lessors held valid tax residency certificates, carried on genuine business activity, and no sham, round-tripping, or dominant tax-avoidance purpose was shown. Treaty relief could not be denied merely by invoking the MLI Principal Purpose Test without domestic incorporation through notification under section 90(1), and the facts did not establish a fixed place permanent establishment because the aircraft were not at the lessors' disposal. Delayed payment or penal charges for lease rentals were also held not taxable, as they were not business income in the absence of a PE and were excluded from ordinary interest treatment under the treaty; relief was extended consistently with the exempt lease rentals. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780420