https://www.taxtmi.com/caselaws?id=778224 Singapore-resident shipping income from international traffic fell within Article 8 of the India-Singapore DTAA, which allocates exclusive taxing rights to the State of residence, so India could not tax the same income under section 44B. Article 24 was treated as a limitation-of-relief provision, applicable only where the source State gives exemption or a reduced rate and the residence State taxes on a remittance basis; because Singapore taxed the income on an accrual basis, that article did not apply. The Tribunal therefore deleted the Indian addition and accepted treaty relief in favour of the assessee. en-us Tue, 19 Aug 2025 00:00:00 +0530 Fri, 12 Sep 2025 08:45:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778224 Singapore-resident shipping income from international traffic fell within Article 8 of the India-Singapore DTAA, which allocates exclusive taxing rights to the State of residence, so India could not tax the same income under section 44B. Article 24 was treated as a limitation-of-relief provision, applicable only where the source State gives exemption or a reduced rate and the residence State taxes on a remittance basis; because Singapore taxed the income on an accrual basis, that article did not apply. The Tribunal therefore deleted the Indian addition and accepted treaty relief in favour of the assessee. Case-Laws Income Tax Tue, 19 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778224