Aircraft Lease Income Held Not Taxable in India Under Article 8 DTAA: ITAT Mumbai

Advertisement Sky High Lxxix Leasing Co. Ltd. Vs ACIT (IT) (ITAT Mumbai) The appeals were filed by various assessees against assessment orders passed under Section 143(3) read with Section 144C(13) for AY 2022-23. The common issue was whether income earned from leasing aircraft to Indian airlines was taxable in India. The Tribunal considered ITA No. 1546/Mum/2025 as the lead case. The assessee, an Ireland tax resident and a special purpose vehicle of the ICBC Leasing group, leased aircraft to Indian airlines on a dry lease basis and filed its return declaring nil income, claiming exemption ...