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“limitation of benefits clause”

International TaxDTAADTAA5 judgments

SKY HIGH II LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1550/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures

SKY HIGH LXXX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1549/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures

SKY HIGH LXXVIII LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1548/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures

SKY HIGH XC LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1547/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23
Section 143(3)Section 234B

satisfied is based only on\nreasonableness and not strictly evidence based.\n(ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause),\nhence the precedents like Tiger Global International III Holdings v. AAR\n[2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV\nbased

SKY HIGH LXXIX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1546/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures