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 operating lease agreements, for leasing aircraft (MSNs 8768, 8710, and 8952). The lease agre...