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        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

        Provisions expressly mentioned in the judgment/order text.

        <h1>Aircraft leasing: MLI PPT not applicable without section 90(1) notification; operating leases and Article 8(1) allocate rental tax to Ireland.</h1> The Tribunal ruled that Articles 6-7 of the MLI cannot be applied against the India-Ireland DTAA without a specific section 90(1) notification; alternatively, the Revenue failed to show PPT-based abuse. Contractual and regulatory analysis classified the transactions as operating leases; no fixed place PE existed in India; and Article 8(1) allocates taxing rights on rental of aircraft in international traffic to Ireland.

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