https://www.taxtmi.com/caselaws?id=754266 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits from international traffic to the State of residence, and Indian tax cannot be levied merely because the income is exempt under Singapore domestic law. The decisive distinction is whether the Singapore income is taxed on an accrual basis or only on a remittance basis: where the taxpayer shows accrual-based taxation in Singapore, Article 24, being a limitation-of-relief provision aimed at remittance-based taxation, does not apply. On that footing, treaty protection is not denied, and the income is not brought to tax in India under section 44B. en-us Wed, 29 May 2024 00:00:00 +0530 Wed, 19 Jun 2024 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754266 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits from international traffic to the State of residence, and Indian tax cannot be levied merely because the income is exempt under Singapore domestic law. The decisive distinction is whether the Singapore income is taxed on an accrual basis or only on a remittance basis: where the taxpayer shows accrual-based taxation in Singapore, Article 24, being a limitation-of-relief provision aimed at remittance-based taxation, does not apply. On that footing, treaty protection is not denied, and the income is not brought to tax in India under section 44B. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754266