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    <title>Decision finds helicopter lease agreements are operating leases and lease rentals fall under Article 8 DTAA, granting treaty relief</title>
    <link>https://www.taxtmi.com/highlights?id=94195</link>
    <description>ITAT held that the lease agreements for helicopters constitute operating leases, not financial leases, and accordingly decided the characterization issue in favour of the assessee and against the Revenue; the Assessing Officer is directed to give effect to this determination. ITAT further held that lease rentals received by the appellant fall within Article 8 of the India-Ireland DTAA, entitling the assessee to treaty relief on such income; this issue is likewise decided in favour of the assessee and against the Revenue, and the Assessing Officer is directed to implement the treaty benefit. Both determinations follow the Tribunal&#039;s prior coordinate-bench reasoning and dispose of the appeal accordingly.</description>
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    <pubDate>Sat, 15 Nov 2025 07:56:56 +0530</pubDate>
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      <title>Decision finds helicopter lease agreements are operating leases and lease rentals fall under Article 8 DTAA, granting treaty relief</title>
      <link>https://www.taxtmi.com/highlights?id=94195</link>
      <description>ITAT held that the lease agreements for helicopters constitute operating leases, not financial leases, and accordingly decided the characterization issue in favour of the assessee and against the Revenue; the Assessing Officer is directed to give effect to this determination. ITAT further held that lease rentals received by the appellant fall within Article 8 of the India-Ireland DTAA, entitling the assessee to treaty relief on such income; this issue is likewise decided in favour of the assessee and against the Revenue, and the Assessing Officer is directed to implement the treaty benefit. Both determinations follow the Tribunal&#039;s prior coordinate-bench reasoning and dispose of the appeal accordingly.</description>
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      <pubDate>Sat, 15 Nov 2025 07:56:56 +0530</pubDate>
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