Assessee assigning rights to purchase Aircraft in favour of  lessors in Ireland who thereafter purchased Aircraft and gave them on operating lease to assessee. Ownership of Aircraft with lessor Supplementary rent mandatory payment for use of  Aircrafts  allowable as deduction. Supplementary rent exempt from tax in hands of  lessors.  Disallowance cannot be made  for failure to deduct tax at source. Rentals received under agreements executed after 1-4-2007 not chargeable to tax in India as per  Double Taxation Avoidance agreement between India and Ireland. Lease rent cannot be treated as interest.  (AY.2012-13)