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    <title>2017 (10) TMI 105 - ITAT HYDERABAD</title>
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    <description>Freight income from Singapore-resident shipping operations was treated as covered by the India-Singapore DTAA exemption, but the limitation-of-relief clause in Article 24 restricted that benefit where the other State taxes income on a remittance basis. Additional evidence and the remand report showed further remittances to Singapore, so treaty relief remained available for the portion proved to have been remitted. Exemption could not be denied for remitted income, but the balance, for which no proof of remittance was furnished, remained taxable in India. The note therefore states that relief was allowed only to the extent of established remittance, with the unproved portion sustained to tax.</description>
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    <pubDate>Fri, 29 Sep 2017 00:00:00 +0530</pubDate>
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      <title>2017 (10) TMI 105 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=348950</link>
      <description>Freight income from Singapore-resident shipping operations was treated as covered by the India-Singapore DTAA exemption, but the limitation-of-relief clause in Article 24 restricted that benefit where the other State taxes income on a remittance basis. Additional evidence and the remand report showed further remittances to Singapore, so treaty relief remained available for the portion proved to have been remitted. Exemption could not be denied for remitted income, but the balance, for which no proof of remittance was furnished, remained taxable in India. The note therefore states that relief was allowed only to the extent of established remittance, with the unproved portion sustained to tax.</description>
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      <pubDate>Fri, 29 Sep 2017 00:00:00 +0530</pubDate>
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