https://www.taxtmi.com/caselaws?id=781439 Helicopter lease terms that did not transfer ownership and required return of the aircraft on expiry were treated as operating leases, not financial leases, because the arrangement matched earlier coordinate bench rulings and the revenue showed no distinguishing feature. The lease rentals received by non-resident lessors were also covered by Article 8 of the India-Ireland DTAA, as profits from the operation or rental of aircraft in international traffic. On that basis, the core additions were deleted on merits, and the remaining grounds were dealt with as consequential, premature, not pressed, or left open. en-us Fri, 31 Oct 2025 00:00:00 +0530 Sat, 15 Nov 2025 07:56:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781439 Helicopter lease terms that did not transfer ownership and required return of the aircraft on expiry were treated as operating leases, not financial leases, because the arrangement matched earlier coordinate bench rulings and the revenue showed no distinguishing feature. The lease rentals received by non-resident lessors were also covered by Article 8 of the India-Ireland DTAA, as profits from the operation or rental of aircraft in international traffic. On that basis, the core additions were deleted on merits, and the remaining grounds were dealt with as consequential, premature, not pressed, or left open. Case-Laws Income Tax Fri, 31 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781439