https://www.taxtmi.com/caselaws?id=442599 Article 24 of the India-Singapore DTAA does not restrict Article 8 treaty relief where the Singapore tax authorities certify that the relevant income is taxed on an accrual basis without reference to remittance; on that footing, the limitation-of-relief clause does not apply. Shipping freight income covered by Article 8 remains outside Indian tax where treaty conditions are satisfied, and the disputed receipts could not be denied treaty protection merely on the Revenue's objections. The commentary also notes that Section 44B was not applied to bring the shipping income to tax in India in these circumstances. 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 Article 24 of the India-Singapore DTAA does not restrict Article 8 treaty relief where the Singapore tax authorities certify that the relevant income is taxed on an accrual basis without reference to remittance; on that footing, the limitation-of-relief clause does not apply. Shipping freight income covered by Article 8 remains outside Indian tax where treaty conditions are satisfied, and the disputed receipts could not be denied treaty protection merely on the Revenue's objections. The commentary also notes that Section 44B was not applied to bring the shipping income to tax in India in these circumstances. Case-Laws Income Tax Wed, 30 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442599