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of The ITAT held that income derived from operation of ships by a Singapore-based assessee is taxable exclusively in Singapore under Article 8 of the India-Singapore DTAA. The AO's invocation of Article 24 to restrict relief only to amounts actually received in Singapore was rejected, as the income is taxable on an accrual basis, not receipt basis, corroborated by a certificate from IRAS. The tribunal relied on precedent from a coordinate bench, which the AO failed to distinguish or appropriately consider. Consequently, the addition made by the AO on account of invoking Article 24 was set aside. The assessee's appeal was allowed, and the AO was directed to delete the impugned addition, affirming the applicability of Article 8 benefits without limitation under Article 24 in this case.
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