https://www.taxtmi.com/caselaws?id=190613 Article 24 of the India-Singapore Treaty was held inapplicable because it targets income exempt or taxed at a reduced rate in one Contracting State and taxed on a remittance basis in the other. The payment was treated as not arising in India under Article 12(7) since the payer was a Singapore resident, making Singapore the source state for royalties. As the income was therefore not income from sources in India, the limitation-of-relief provision did not operate. The amount was also taxed in Singapore under domestic law, which further supported treaty eligibility. The assessee was entitled to treaty benefit. en-us Fri, 11 Feb 2011 00:00:00 +0530 Tue, 25 Apr 2023 09:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190613 Article 24 of the India-Singapore Treaty was held inapplicable because it targets income exempt or taxed at a reduced rate in one Contracting State and taxed on a remittance basis in the other. The payment was treated as not arising in India under Article 12(7) since the payer was a Singapore resident, making Singapore the source state for royalties. As the income was therefore not income from sources in India, the limitation-of-relief provision did not operate. The amount was also taxed in Singapore under domestic law, which further supported treaty eligibility. The assessee was entitled to treaty benefit. Case-Laws Income Tax Fri, 11 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190613