MLI provisions unenforceable sans separate notification: ITAT Mumbai

Sky High Appeal XLIII Leasing Company Limited Vs ACIT (ITAT Mumbai)

ITAT Mumbai: MLI provisions unenforceable sans separate notification; Relies on Nestle, highlights Revenue’s contradicting stand.

Facts:

• The assessee, Irish companies, are part of international aircraft leasing groups, that is, TFDAC, and are recognized tax residents of Ireland, holding valid Irish Tax Residency Certificates (TRCs).
• They leased aircraft to InterGlobe Aviation Ltd. (in brief, IndiGo), on 1 February 2019 under dry oper

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