https://www.taxtmi.com/highlights?id=94264 The ITAT allowed the taxpayer's appeal, holding that the taxpayer, a Singapore resident portfolio company wholly owned by a sovereign investment vehicle, possessed sufficient economic substance, independent management and operational control in Singapore and therefore did not qualify as a conduit or shell. The Tribunal found the pre-1/4/2017 share acquisition qualified for taxation solely in Singapore under Article 13(4)/(4A) of the India-Singapore DTAA and that the subsequent sale to an unrelated foreign purchaser was a genuine commercial realization. Applying Article 24A(1)-(2) (PPT), the Tribunal concluded that obtaining a treaty benefit was not one of the principal purposes and accordingly upheld the treaty exemption of the capital gain. en-us Tue, 18 Nov 2025 08:42:58 +0530 Tue, 18 Nov 2025 08:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94264 The ITAT allowed the taxpayer's appeal, holding that the taxpayer, a Singapore resident portfolio company wholly owned by a sovereign investment vehicle, possessed sufficient economic substance, independent management and operational control in Singapore and therefore did not qualify as a conduit or shell. The Tribunal found the pre-1/4/2017 share acquisition qualified for taxation solely in Singapore under Article 13(4)/(4A) of the India-Singapore DTAA and that the subsequent sale to an unrelated foreign purchaser was a genuine commercial realization. Applying Article 24A(1)-(2) (PPT), the Tribunal concluded that obtaining a treaty benefit was not one of the principal purposes and accordingly upheld the treaty exemption of the capital gain. Highlights Income Tax Tue, 18 Nov 2025 08:42:58 +0530 https://www.taxtmi.com/highlights?id=94264