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No PE in India for Irish Aircraft Lessor – Lease Rentals Taxable Only in Ireland under DTAA
Case Law Details
- Case Name
- Sky High Appeal XLIII Leasing Company Limited Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Mumbai
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Sky High Appeal XLIII Leasing Company Limited Vs ACIT (ITAT Mumbai)
Background: The case before the Income Tax Appellate Tribunal (ITAT) Mumbai concerned the taxability of aircraft lease rentals received by Sky High Appeal XLIII Leasing Company Limited, an Irish enterprise, from IndiGo Airlines. The primary issue was whether the leased aircraft gave rise to a Permanent Establishment (PE) of the lessor in India under Article 5 of the India–Ireland Double Taxation Avoidance Agreement (DTAA). If a PE existed, the lease rentals could be taxed in India under Article 7 of the DTA...
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