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of <h1>Claim for tax relief under India-Singapore Treaty Article 8 and reliance on Article 24 under s.172(4) ITA</h1> HC considered claim for tax relief under Article 8 of the India-Singapore Treaty and reliance on Article 24 under s.172(4) of the Income Tax Act. The ... Tax relief as per article 8 of the India - Singapore Treaty by relying upon article 24 of the said Treaty under Section 172(4) of the Income Tax Act, 1961 - HELD THAT:- With regard to the merits of the matter, it was submitted that the Respondent shall also make appropriate and suitable averments in the Affidavit which may be filed. Considering the above submission, issue notice, returnable on 16.06.2025. To be listed on top of the board. The Income Tax Appellate Tribunal remanded the matter to the Assessing Officer to 'verify the contents of the certificate issued by the Singapore Tax Authority' and directed that if the department is 'unable to obtain any specific material to rebut the contents of the certificate,' relief may be granted to the assessee in accordance with law. Despite that direction, the Assessing Officer passed an assessment rejecting the petitioner's claim for tax relief under Article 8 of the India-Singapore DTAA and made additions by relying on Article 24 and Section 172(4) of the Income Tax Act, 1961. In para 8.1 the Assessing Officer rebutted the petitioner, stating: 'Further, the Hon'ble ITAT has not accepted or guaranteed the TRC issued by the IRAS. The observation of the ITAT granting relief as per Assessee's own case decision of Hon'ble Gujarat High Court. Corresponding to this claim, the Hon'ble ITAT ought to have given the Vessel name and AY of such orders. As far as the Hon'ble High Court decision is applicable only for M.T. Mearsk, not for others. The assessee/agent case has not yet been decided by the Hon'ble High Court. The ITAT had erred in making such comments, i.e., assessee's own case, nothing more.' The respondent admitted the petitioner's contention and agreed to file an appropriate affidavit; notice issued returnable 16.06.2025.
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