https://www.taxtmi.com/caselaws?id=443791 A Singapore Tax Residency Certificate was treated as sufficient evidence of residence for India-Singapore DTAA purposes, and treaty benefit was upheld on capital gains from sale of CCDs. The Tribunal accepted that the assessee had commercial substance in Singapore, supported by business activity, expenditure above the treaty threshold, banking and operational presence, and board-level management outside India. Revenue objections based on limitation of benefits, look-through, substance-over-form, control and management, and treaty shopping were rejected on the facts, as the treaty benefit could not be denied without proof that the arrangement was a sham or lacked genuine business substance. en-us Fri, 12 May 2023 00:00:00 +0530 Sat, 30 Sep 2023 13:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443791 A Singapore Tax Residency Certificate was treated as sufficient evidence of residence for India-Singapore DTAA purposes, and treaty benefit was upheld on capital gains from sale of CCDs. The Tribunal accepted that the assessee had commercial substance in Singapore, supported by business activity, expenditure above the treaty threshold, banking and operational presence, and board-level management outside India. Revenue objections based on limitation of benefits, look-through, substance-over-form, control and management, and treaty shopping were rejected on the facts, as the treaty benefit could not be denied without proof that the arrangement was a sham or lacked genuine business substance. Case-Laws Income Tax Fri, 12 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443791