https://www.taxtmi.com/caselaws?id=346348 ITAT held for the assessee that shipping income falls exclusively under Article 8 of the India-Singapore DTAA and is taxable by the resident state on an accrual basis, so Article 24's limitation clause cannot be invoked to deny treaty benefit. The AO and CIT(A) were not justified in correlating remittances or disputing the foreign tax certificate; they lack jurisdiction once Article 8 applies. Orders of AO and CIT(A) were set aside and benefit of Article 8 was directed to be allowed for all voyages. 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 ITAT held for the assessee that shipping income falls exclusively under Article 8 of the India-Singapore DTAA and is taxable by the resident state on an accrual basis, so Article 24's limitation clause cannot be invoked to deny treaty benefit. The AO and CIT(A) were not justified in correlating remittances or disputing the foreign tax certificate; they lack jurisdiction once Article 8 applies. Orders of AO and CIT(A) were set aside and benefit of Article 8 was directed to be allowed for all voyages. Case-Laws Income Tax Fri, 16 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346348