Article 8 DTAA: Aircraft leasing and deferred lease interest treated as lease income, PPT/MLI not denying treaty benefits

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....ITAT affirmed that the assessee's income from aircraft leasing is not taxable in India under Article 8 of the India-Ireland DTAA, following the coordinate-bench precedent. The Tribunal held that interest on deferred lease payments, being charged for delayed lease rentals and directly connected to aircraft operations, constitutes an integral component of lease income and therefore falls within Article 8 rather than separate interest provisions. Consequently, benefits under the DTAA are not denied by the PPT/MLI in this context. The AO is directed to allow the assessee's claim that the impugned income is not chargeable to tax, to verify whether such interest was included in prior additions to leasing profits, and to give effect to this order.....