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    <title>2024 (3) TMI 1120 - ITAT RAJKOT</title>
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    <description>Treaty relief under Article 8 of the India-Singapore DTAA had to be read with Article 24 so that limitation of relief did not become redundant or permit unintended double non-taxation. The Singapore tax authority certificate supporting the claim that freight income was taxable in Singapore on an accrual basis was treated as insufficiently explained, because it did not clearly state the factual or statutory basis for that conclusion and the Department had challenged it. The matter was therefore remitted to the Assessing Officer for verification of the certificate, with treaty relief to follow only if the certificate is not rebutted in accordance with law.</description>
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      <description>Treaty relief under Article 8 of the India-Singapore DTAA had to be read with Article 24 so that limitation of relief did not become redundant or permit unintended double non-taxation. The Singapore tax authority certificate supporting the claim that freight income was taxable in Singapore on an accrual basis was treated as insufficiently explained, because it did not clearly state the factual or statutory basis for that conclusion and the Department had challenged it. The matter was therefore remitted to the Assessing Officer for verification of the certificate, with treaty relief to follow only if the certificate is not rebutted in accordance with law.</description>
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