https://www.taxtmi.com/caselaws?id=346348 Article 24(1) of the India-Singapore DTAA applies only where the other Contracting State taxes income by reference to remittance or receipt, not where tax is levied on accrual. Because the Singapore authority certificate showed the shipping income was assessable in Singapore on an accrual basis, the remittance-based limitation clause failed. Article 8 therefore remained operative, and treaty protection for the Singapore resident enterprise's shipping income could not be denied on a non-remittance basis. en-us Fri, 16 Jun 2017 00:00:00 +0530 Mon, 08 Sep 2025 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346348 Article 24(1) of the India-Singapore DTAA applies only where the other Contracting State taxes income by reference to remittance or receipt, not where tax is levied on accrual. Because the Singapore authority certificate showed the shipping income was assessable in Singapore on an accrual basis, the remittance-based limitation clause failed. Article 8 therefore remained operative, and treaty protection for the Singapore resident enterprise's shipping income could not be denied on a non-remittance basis. Case-Laws Income Tax Fri, 16 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346348