https://www.taxtmi.com/caselaws?id=776253 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits from international traffic exclusively to the State of residence, and does not operate as a source-State exemption provision. Article 24 applies only where treaty relief in the source State is linked to exemption or a reduced rate and the same income is taxable in the other State on remittance or receipt basis. Because the assessee's shipping income was taxable in Singapore on accrual basis, those conditions were not met. The source State could not invoke Article 24 to curtail Article 8, and the Indian addition was liable to be deleted. en-us Fri, 25 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 07:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776253 Article 8 of the India-Singapore DTAA allocates taxing rights over shipping profits from international traffic exclusively to the State of residence, and does not operate as a source-State exemption provision. Article 24 applies only where treaty relief in the source State is linked to exemption or a reduced rate and the same income is taxable in the other State on remittance or receipt basis. Because the assessee's shipping income was taxable in Singapore on accrual basis, those conditions were not met. The source State could not invoke Article 24 to curtail Article 8, and the Indian addition was liable to be deleted. Case-Laws Income Tax Fri, 25 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776253