https://www.taxtmi.com/caselaws?id=430995 Article 8 of the India-Singapore DTAA allocates exclusive taxing rights over qualifying shipping profits to Singapore, preventing Indian taxation of freight income from voyages originating at Indian ports. Article 24 restricts treaty relief only where Singapore taxes the income by reference to remittance or receipt rather than the full amount. Singapore shipping income is assessable on an accrual basis, making physical remittance irrelevant and leaving Article 24 inapplicable. Domestic shipping-incentive exemptions in Singapore do not alter Article 8's allocation of taxing rights. Consequently, qualifying freight income remains outside Indian tax 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 exclusive taxing rights over qualifying shipping profits to Singapore, preventing Indian taxation of freight income from voyages originating at Indian ports. Article 24 restricts treaty relief only where Singapore taxes the income by reference to remittance or receipt rather than the full amount. Singapore shipping income is assessable on an accrual basis, making physical remittance irrelevant and leaving Article 24 inapplicable. Domestic shipping-incentive exemptions in Singapore do not alter Article 8's allocation of taxing rights. Consequently, qualifying freight income remains outside Indian tax under section 172. Case-Laws Income Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430995