https://www.taxtmi.com/caselaws?id=400812 ITAT held for the taxpayer, directing deletion of additions of shipping income earned in India. The tribunal found the AO erred in invoking Article 24 of the India-Singapore DTAA; Article 8 grants the State of residence exclusive taxing rights over profits from operation of ships in international traffic, precluding India from taxing such income even if India-sourced. The AO's reliance on Singapore's domestic Section 13F and remittance concepts was misplaced. The tribunal noted Singapore taxes such income on an accrual basis and that DTAA conditions for Article 24 relief were not met. en-us Fri, 06 Nov 2020 00:00:00 +0530 Mon, 08 Sep 2025 14:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400812 ITAT held for the taxpayer, directing deletion of additions of shipping income earned in India. The tribunal found the AO erred in invoking Article 24 of the India-Singapore DTAA; Article 8 grants the State of residence exclusive taxing rights over profits from operation of ships in international traffic, precluding India from taxing such income even if India-sourced. The AO's reliance on Singapore's domestic Section 13F and remittance concepts was misplaced. The tribunal noted Singapore taxes such income on an accrual basis and that DTAA conditions for Article 24 relief were not met. Case-Laws Income Tax Fri, 06 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400812