Aircraft Lease Income Held Not Taxable Under Article 8 of India-Ireland DTAA: ITAT Mumbai

Advertisement Sunflower Aircraft Leasing Limited Vs ACIT (ITAT Mumbai) The assessee appealed against the final assessment order passed under Section 143(3) read with Section 144C(13) of the Income-tax Act for AY 2022-23. The dispute concerned the taxability in India of lease rentals earned by an Irish tax resident company from leasing two Airbus A320 aircraft to InterGlobe Aviation Limited (IndiGo). The assessee contended that the income was either taxable only in Ireland under Article 7 of the India-Ireland DTAA due to the absence of a Permanent Establishment (PE) in India or, alternativel...