https://www.taxtmi.com/caselaws?id=442695 Valid Singapore tax residency evidence, audited accounts and operational records were accepted to support India-Singapore DTAA relief, and the Revenue's treaty-shopping and GAAR-style objections failed on the facts found. The Tribunal held that the share transfer gains were not taxable in India because the record did not show control outside Singapore or any impermissible conduit benefit. On the capital loss issue, the share premium was treated as part of the acquisition cost because it was supported by the books and corporate records, and the Assessing Officer could not disregard binding DRP directions by introducing a new disallowance basis in the final assessment. en-us Wed, 23 Aug 2023 00:00:00 +0530 Tue, 26 Nov 2024 16:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442695 Valid Singapore tax residency evidence, audited accounts and operational records were accepted to support India-Singapore DTAA relief, and the Revenue's treaty-shopping and GAAR-style objections failed on the facts found. The Tribunal held that the share transfer gains were not taxable in India because the record did not show control outside Singapore or any impermissible conduit benefit. On the capital loss issue, the share premium was treated as part of the acquisition cost because it was supported by the books and corporate records, and the Assessing Officer could not disregard binding DRP directions by introducing a new disallowance basis in the final assessment. Case-Laws Income Tax Wed, 23 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442695