https://www.taxtmi.com/caselaws?id=383452 Article 8 of the Indo-Singapore DTAA governs profits from the operation of ships in international traffic, while Article 24 applies only where the income is taxed in the other State by reference to remittance or receipt. The Tribunal noted that the assessee's reliance on prior material and the Maersk Mikage ruling was fact-specific, but the record here did not establish that the voyage income had been assessed in Singapore on an accrual basis or that the relevant tax treatment was proved by supporting evidence. The matter therefore required fresh verification by the Assessing Officer, and the demand could not be sustained on the existing record. en-us Wed, 03 Jul 2019 00:00:00 +0530 Tue, 23 Jul 2019 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383452 Article 8 of the Indo-Singapore DTAA governs profits from the operation of ships in international traffic, while Article 24 applies only where the income is taxed in the other State by reference to remittance or receipt. The Tribunal noted that the assessee's reliance on prior material and the Maersk Mikage ruling was fact-specific, but the record here did not establish that the voyage income had been assessed in Singapore on an accrual basis or that the relevant tax treatment was proved by supporting evidence. The matter therefore required fresh verification by the Assessing Officer, and the demand could not be sustained on the existing record. Case-Laws Income Tax Wed, 03 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383452