Aircraft Leasing Revenue Not Taxable Under India-Ireland DTAA: Delhi HC

Milestone Aviation Asset Holding Group No. 25 Ltd. Vs ACIT (Delhi High Court) Delhi High Court held that as per Article 12 of India-Ireland DTAA revenue receipt from aircraft leasing is outside the purview of taxation. Thus, it is impermissible to invoke section 9(1)(vi) in light of express exemption under DTAA. Facts- The instant writ petition impugns the reassessment action which has been initiated for Assessment Year 2016-2017. As is manifest from the reasons which have been ascribed and which appear to have weighed upon the Assessing Officer to come to the conclusion that income had escape...