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The Delhi High Court ruling in (2022) 443ITR441 emphasised the importance of rule 28AA and denounced action of the AO in stepping out of rule 28AA and denying benefit of DTAA and insisted for 10% TDS on receipt of aircraft lease rentals by Ireland based aircraft leasing company. In the past nil certificates were issued.


In this case there had been a survey action and reopening of group companies of the applicant which overturned the view held earlier on the premise that survey action may fasten demand even upon the assessee. 

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