https://www.taxtmi.com/caselaws?id=265993 Article 24 of the India-Singapore DTAA cannot be used to deny treaty relief where the relevant freight income is Singapore-sourced and taxable in Singapore on an accrual basis. The limitation-of-benefits condition applies only when source-state relief is linked to taxation in the residence state by reference to remittance or receipt, not where the income is taxed on the full amount on accrual. On the facts described, Singapore tax authority confirmation and the accountant's certificate showed the income was included in global income and taxed in Singapore, so the precondition for Article 24 was absent and no further proof of remittance to Singapore was required. The freight income from ships in international traffic remained taxable only in Singapore. en-us Fri, 09 Oct 2015 00:00:00 +0530 Sat, 17 Oct 2015 08:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265993 Article 24 of the India-Singapore DTAA cannot be used to deny treaty relief where the relevant freight income is Singapore-sourced and taxable in Singapore on an accrual basis. The limitation-of-benefits condition applies only when source-state relief is linked to taxation in the residence state by reference to remittance or receipt, not where the income is taxed on the full amount on accrual. On the facts described, Singapore tax authority confirmation and the accountant's certificate showed the income was included in global income and taxed in Singapore, so the precondition for Article 24 was absent and no further proof of remittance to Singapore was required. The freight income from ships in international traffic remained taxable only in Singapore. Case-Laws Income Tax Fri, 09 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265993