https://www.taxtmi.com/caselaws?id=795987 Treaty modifications under the Multilateral Instrument cannot restrict India-Ireland treaty benefits unless their domestic effect is separately notified under section 90(1), so the Principal Purpose Test was inapplicable on the stated analysis. The notes characterise the aircraft arrangements as operating leases: aircraft rentals were neither interest nor equipment royalty because title and residual risks remained with the lessor and aircraft are excluded from equipment royalty. They further explain that dry-leased aircraft under the lessee's operational control do not create a fixed place permanent establishment, while qualifying international aircraft-rental income falls exclusively within Article 8 taxation in Ireland. en-us Thu, 30 Apr 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795987 Treaty modifications under the Multilateral Instrument cannot restrict India-Ireland treaty benefits unless their domestic effect is separately notified under section 90(1), so the Principal Purpose Test was inapplicable on the stated analysis. The notes characterise the aircraft arrangements as operating leases: aircraft rentals were neither interest nor equipment royalty because title and residual risks remained with the lessor and aircraft are excluded from equipment royalty. They further explain that dry-leased aircraft under the lessee's operational control do not create a fixed place permanent establishment, while qualifying international aircraft-rental income falls exclusively within Article 8 taxation in Ireland. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795987