ORDER 

PER M. BALAGANESH, A. M.:

1. By virtue of these stay applications, the assessees seek to keep the demand raised for the AY 2022-23 in abeyance.

2. We have heard the rival submissions and perused the material available on record. The assessee is based on Ireland, engaged in the business of leasing aircraft. The assessee is a tax resident of Ireland. The assessee had leased aircraft to an Indian entity on operating lease basis and received lease rentals thereon. The lease rental income of the assessee is not taxable in India under India-Ireland Double Taxation Agreement (DTAA). In the assessment proceedings, the ld AO re-characterized the operating lease as finance lease in the draft assessment order by holding that return of aircraft at the end of lease period tantamount to repayment of principal portion of the finance lease. The assessee filed objections before the ld DRP which upheld the draft assessment order. The assessee submitted that Special Bench of Delhi Tribunal in