https://www.taxtmi.com/caselaws?id=341132 Article 13(4) of the India-Singapore tax treaty exempts capital gains on alienation of property by a Singapore resident from Indian tax, and Article 24 is a limitation provision aimed at source-country relief where the other state taxes income on a remittance basis. On the stated facts, the Singapore tax certificate showed accrual-basis taxation in Singapore as Singapore-sourced income, without any remittance condition. The Tribunal followed coordinate bench and Gujarat High Court authority and concluded that Article 24 was not triggered merely because remittance to Singapore was not shown. The treaty benefit under Article 13(4) therefore remained available and the capital gains were not taxable in India. en-us Fri, 24 Mar 2017 00:00:00 +0530 Mon, 03 Apr 2017 08:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341132 Article 13(4) of the India-Singapore tax treaty exempts capital gains on alienation of property by a Singapore resident from Indian tax, and Article 24 is a limitation provision aimed at source-country relief where the other state taxes income on a remittance basis. On the stated facts, the Singapore tax certificate showed accrual-basis taxation in Singapore as Singapore-sourced income, without any remittance condition. The Tribunal followed coordinate bench and Gujarat High Court authority and concluded that Article 24 was not triggered merely because remittance to Singapore was not shown. The treaty benefit under Article 13(4) therefore remained available and the capital gains were not taxable in India. Case-Laws Income Tax Fri, 24 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341132