https://www.taxtmi.com/caselaws?id=795987 Multilateral Instrument modifications, including the Principal Purpose Test, cannot restrict India-Ireland treaty benefits unless separately incorporated through notification under Section 90(1). Aircraft leases retaining title, residual risks, repossession rights and re-leasing rights with the lessor are operating leases, so rentals are neither interest nor equipment royalty; aircraft are expressly excluded from equipment royalty. Dry-leased aircraft under the lessee's operational possession and control do not create a fixed place permanent establishment for the foreign lessor. Qualifying aircraft-rental income from international traffic is governed exclusively by Article 8 in Ireland, without requiring the lessor to operate the aircraft or prove predominant international use. 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 Multilateral Instrument modifications, including the Principal Purpose Test, cannot restrict India-Ireland treaty benefits unless separately incorporated through notification under Section 90(1). Aircraft leases retaining title, residual risks, repossession rights and re-leasing rights with the lessor are operating leases, so rentals are neither interest nor equipment royalty; aircraft are expressly excluded from equipment royalty. Dry-leased aircraft under the lessee's operational possession and control do not create a fixed place permanent establishment for the foreign lessor. Qualifying aircraft-rental income from international traffic is governed exclusively by Article 8 in Ireland, without requiring the lessor to operate the aircraft or prove predominant international use. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795987