https://www.taxtmi.com/caselaws?id=439648 Article 13(4) of the India-Singapore DTAA was applied to gains from alienation of debt instruments, so the gains were taxable only in Singapore. Article 24 was held to be inapplicable because the Singapore tax certificate stated that the income was taxable there without reference to the amount remitted or received, and that limitation clause operates only where relief is linked under the other State's law to remittance-based taxation. The certificate was treated as sufficient evidence of the Singapore tax position, and the Assessing Officer could not replace it with his own interpretation of Singapore law. On that basis, the treaty benefit under Article 13(4) was upheld. en-us Wed, 21 Jun 2023 00:00:00 +0530 Fri, 15 May 2026 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439648 Article 13(4) of the India-Singapore DTAA was applied to gains from alienation of debt instruments, so the gains were taxable only in Singapore. Article 24 was held to be inapplicable because the Singapore tax certificate stated that the income was taxable there without reference to the amount remitted or received, and that limitation clause operates only where relief is linked under the other State's law to remittance-based taxation. The certificate was treated as sufficient evidence of the Singapore tax position, and the Assessing Officer could not replace it with his own interpretation of Singapore law. On that basis, the treaty benefit under Article 13(4) was upheld. Case-Laws Income Tax Wed, 21 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439648