Held that cross border lease agreements for aircrafts which were executed prior to 1-4-2007, since supplementary rent was determined taking into consideration number of flying hours and had character of basic rent, said payment would be exempt from tax in hands of lessors in India as per section 10(15A) and disallowance under section 40(a)(i) could not be made. Tribunal also held that by introduction of Finance Act, 2005 exemption under section 10(15A) was withdrawn for cross-border leasing agreements of aircrafts entered into after 1-4-2007 and provisions of bilateral tax treaties would apply-Whether as per articles 12 and 8 of tax treaty with Ireland, profits derived by an enterprise of contracting State from rental of aircrafts were taxable only in State of residence of lessor, thus, supplementary rent paid for lease agreements executed after 1-4-2007 would not be chargeable to tax in India  (AY. 2012-13)