S. 40(a)(i) : Amounts not deductible-Deduction at source-Aircrafts-Supplementary rent in respect of cross border lease agreements-Exempt from tax-No disallowance can be made for failure to deduct tax at source-Shipping, inland waterways transport and air-transport-In respect of agreement executed after 1-4-2007 as per articles 12 and 8 of DTAA between India and Ireland, profits derived by an enterprise of contracting State from rental of aircrafts were taxable only in State of residence of lessor-DTAA-India-Ireland. [S. 9(1)(i), 10(15A), 195, Art. 8, 12]