Just a moment...

⚠✕
❮ Top
☎ Help
Upgrade to AI Search ✕

We've upgraded AI Search on TaxTMI with two powerful modes:

1. Basic
• Quick overview summary answering your query with references• Category-wise results to explore all relevant documents on TaxTMI

2. Advanced
• Includes everything in Basic
• Detailed report covering:
     -   Overview Summary
     -   Governing Provisions [Acts, Notifications, Circulars]
     -   Relevant Case Laws
     -   Tariff / Classification / HSN
     -   Expert views from TaxTMI
     -   Practical Guidance with immediate steps and dispute strategy

• Also highlights how each document is relevant to your query, helping you quickly understand key insights without reading the full text.Help Us Improve - by giving the rating with each AI Result:

Explore AI Search →

Powered by Weblekha - Building Scalable Websites

☰
×

By creating an account you can:

Logo TaxTMI
>
Keyword Search :
AI Search : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Search ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ----❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    No Records Found
    ❮
    ❯
    ❯❯
    MaximizeMaximizeMaximize
    0 / 200
    Expand Note
    Add to Folder

    No Folders have been created

      +

      Are you sure you want to delete "My most important" ?

      NOTE:

      Open Link
      Highlights
      Showing Results for :
      Reset Filters
      Results Found:
      AI TextQuick Glance by AIHeadnote
      Show All SummariesHide All Summaries
      No Records Found

      Highlights

      Back

      All Highlights

      Showing Results for :
      Reset Filters
      Showing
      Records
      ExpandCollapse
        No Records Found

        Highlights

        Back

        All Highlights

        Showing Results for : Reset Filters
        Case ID :
        Income Tax

        The ITAT allowed the taxpayer's appeal, holding that the...

        Sovereign-owned Singapore portfolio company deemed substantive; capital gain exempt under Article 13(4)/(4A) and Article 24A(1)-(2)

        📋
        Contents
        Note

        Note

        -

        Bookmark

        print

        Print

        Print Options

        Login to TaxTMI
        Verification Pending

        The Email Id has not been verified. Click on the link we have sent on

        Didn't receive the mail? Resend Mail

        Don't have an account? Register Here

                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The ITAT allowed the taxpayer's appeal, holding that the taxpayer, a Singapore resident portfolio company wholly owned by a sovereign investment vehicle, possessed sufficient economic substance, independent management and operational control in Singapore and therefore did not qualify as a conduit or shell. The Tribunal found the pre-1/4/2017 share acquisition qualified for taxation solely in Singapore under Article 13(4)/(4A) of the India-Singapore DTAA and that the subsequent sale to an unrelated foreign purchaser was a genuine commercial realization. Applying Article 24A(1)-(2) (PPT), the Tribunal concluded that obtaining a treaty benefit was not one of the principal purposes and accordingly upheld the treaty exemption of the capital gain.
                                Note: It is a system-generated summary and is for quick reference only.
                                You may also like:

                                  Topics

                                  ActsIncome Tax
                                  No Records Found
                                  Next ➔