https://www.taxtmi.com/caselaws?id=430995 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits to the State of residence, and that treaty benefit is not lost merely because Singapore grants a domestic shipping exemption. Article 24 applies only where the income is exempted or taxed at a reduced rate in the source State and is then taxed in the other State on a remittance or receipt basis; on the facts discussed, Singapore treated the freight income on an accrual basis, so physical remittance was irrelevant and the Article 24 condition was not met. The freight income therefore remained covered by Article 8 relief and was not taxable in India under section 172. en-us Wed, 30 Nov 2022 00:00:00 +0530 Mon, 08 Sep 2025 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430995 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits to the State of residence, and that treaty benefit is not lost merely because Singapore grants a domestic shipping exemption. Article 24 applies only where the income is exempted or taxed at a reduced rate in the source State and is then taxed in the other State on a remittance or receipt basis; on the facts discussed, Singapore treated the freight income on an accrual basis, so physical remittance was irrelevant and the Article 24 condition was not met. The freight income therefore remained covered by Article 8 relief and was not taxable in India under section 172. Case-Laws Income Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430995