https://www.taxtmi.com/caselaws?id=305375 Article 24 of the India-Singapore DTAA was found inapplicable because the disputed royalty income was not taxable in India on the facts and the treaty language did not justify denial of relief. The Tribunal followed an earlier coordinate bench view and held that treaty benefits could not be denied under Article 24. On Article 12(7), royalty was held not to arise in India merely because the payer had a permanent establishment in India; the payer was not resident in India, and there was no economic nexus showing that the liability was incurred in connection with, and borne by, that permanent establishment. The assessee therefore retained DTAA benefits on the disputed payments. en-us Fri, 27 Dec 2013 00:00:00 +0530 Thu, 01 Dec 2022 15:47:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305375 Article 24 of the India-Singapore DTAA was found inapplicable because the disputed royalty income was not taxable in India on the facts and the treaty language did not justify denial of relief. The Tribunal followed an earlier coordinate bench view and held that treaty benefits could not be denied under Article 24. On Article 12(7), royalty was held not to arise in India merely because the payer had a permanent establishment in India; the payer was not resident in India, and there was no economic nexus showing that the liability was incurred in connection with, and borne by, that permanent establishment. The assessee therefore retained DTAA benefits on the disputed payments. Case-Laws Income Tax Fri, 27 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305375