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    <title>2025 (11) TMI 1491 - ITAT DELHI</title>
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    <description>ITAT Delhi held that the lease agreements between the assessee lessors and aviation company lessees for Airbus aircrafts are operating leases, following its earlier ruling in Celestial Aviation Trading. Consequently, the transactions were not treated as finance leases for tax purposes. On the issue of eligibility for relief under Article 8 of the India-Ireland DTAA, the ITAT applied its earlier decision in Kosi Aviation Leasing Ltd and denied the benefit, holding that the assessee was not entitled to Article 8 protection. The assessees&#039; appeals were dismissed accordingly.</description>
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    <pubDate>Wed, 29 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1491 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782023</link>
      <description>ITAT Delhi held that the lease agreements between the assessee lessors and aviation company lessees for Airbus aircrafts are operating leases, following its earlier ruling in Celestial Aviation Trading. Consequently, the transactions were not treated as finance leases for tax purposes. On the issue of eligibility for relief under Article 8 of the India-Ireland DTAA, the ITAT applied its earlier decision in Kosi Aviation Leasing Ltd and denied the benefit, holding that the assessee was not entitled to Article 8 protection. The assessees&#039; appeals were dismissed accordingly.</description>
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