https://www.taxtmi.com/caselaws?id=400812 Shipping income of a Singapore tax resident from operations in India was treated as falling within Article 8 of the India-Singapore DTAA, which allocates taxing rights over profits from ships operated in international traffic to the State of residence. Because the assessee had no permanent establishment in India, the income remained protected by the treaty and could not be taxed in India under domestic law. Article 24 was held inapplicable since it applies only in specific exemption or reduced-rate situations and did not convert Article 8 income into India-taxable income on remittance basis. The addition under section 44B was therefore unsustainable. 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 Shipping income of a Singapore tax resident from operations in India was treated as falling within Article 8 of the India-Singapore DTAA, which allocates taxing rights over profits from ships operated in international traffic to the State of residence. Because the assessee had no permanent establishment in India, the income remained protected by the treaty and could not be taxed in India under domestic law. Article 24 was held inapplicable since it applies only in specific exemption or reduced-rate situations and did not convert Article 8 income into India-taxable income on remittance basis. The addition under section 44B was therefore unsustainable. Case-Laws Income Tax Fri, 06 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400812