https://www.taxtmi.com/caselaws?id=442599 The dispute concerns application of the India-Singapore DTAA to freight income from ships and whether treaty relief must be limited to amounts remitted to Singapore under Article 24. Court reasoned that Article 24 limits relief only where Singapore taxes the income by reference to amounts remitted or received there; where Singapore taxes on the full amount on accrual, Article 24 does not restrict relief. A certificate from the Singapore tax authority confirming accrual taxation was accepted as sufficient evidence. The court therefore upheld DTAA Article 8 benefit for eligible freight receipts and dismissed the appeal, finding no substantial question of law. en-us Wed, 30 Aug 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442599 The dispute concerns application of the India-Singapore DTAA to freight income from ships and whether treaty relief must be limited to amounts remitted to Singapore under Article 24. Court reasoned that Article 24 limits relief only where Singapore taxes the income by reference to amounts remitted or received there; where Singapore taxes on the full amount on accrual, Article 24 does not restrict relief. A certificate from the Singapore tax authority confirming accrual taxation was accepted as sufficient evidence. The court therefore upheld DTAA Article 8 benefit for eligible freight receipts and dismissed the appeal, finding no substantial question of law. Case-Laws Income Tax Wed, 30 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442599