IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.1107/Mum/2025 (Assessment Year :2022-23 &

SA 35/Mum/2025 (Arising out of ITA No.1107/Mum/2025 (Assessment Year :2022-23 M/s. Sunflower Aircraft Vs. Assistant Leasing Limited Commissioner of Aviation House Income Tax Circle Shannon Country Clare 4(2)(2), V14 AN 29 International Tax, C/o. DMD Advocates Mumbai

30, Nizamuddin East, New Delhi-110 013 PAN/GIR No.ABDCS5779F (Appellant) .. (Respondent Assessee by Shri Sachit Jolly, Sr. Advocate Revenue by Shri Krishna Kumar, Sr. DR Date of Hearing 11/08/2025 Date of Pronouncement 13/08/2025 आदेश / O R D E R PER AMIT SHUKLA (J.M):

The aforesaid appeal has been filled by the assessee against the final assessment order dated 19 January 2025, passed under The Aircraft performs 2 functions: Lease income for Applicant, and operational income for Indian Aircraft Operator. It is at the disposal of the Applicant for its lease business.

The lease rental earning activity played by the Aircraft is the function of the applicant and not of Indian lessor. Thus, this function performed by Aircraft from vantage point of Ap