https://www.taxtmi.com/caselaws?id=781589 Treaty protection under Article 13(4A) of the India-Singapore DTAA was available where a Singapore-incorporated, government-owned investment holding company showed board-level control, documented management and operational in Singapore, and genuine commercial substance. The Principal Purpose Test and the shell or conduit restrictions in Article 24A were not satisfied on the facts because the investment was a long-term strategic holding made before the treaty amendment and the arrangement was not principally designed to obtain treaty benefits. The documentary record, including certification from the Singapore tax authority and auditor, supported the expenditure threshold under Article 24A. As a result, the capital gains from the share sale were not taxable in India and the treaty benefit could not be denied. en-us Tue, 28 Oct 2025 00:00:00 +0530 Tue, 18 Nov 2025 08:42:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781589 Treaty protection under Article 13(4A) of the India-Singapore DTAA was available where a Singapore-incorporated, government-owned investment holding company showed board-level control, documented management and operational in Singapore, and genuine commercial substance. The Principal Purpose Test and the shell or conduit restrictions in Article 24A were not satisfied on the facts because the investment was a long-term strategic holding made before the treaty amendment and the arrangement was not principally designed to obtain treaty benefits. The documentary record, including certification from the Singapore tax authority and auditor, supported the expenditure threshold under Article 24A. As a result, the capital gains from the share sale were not taxable in India and the treaty benefit could not be denied. Case-Laws Income Tax Tue, 28 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781589