https://www.taxtmi.com/caselaws?id=786065 Capital gains on transfer of equity shares and compulsorily convertible debentures were treated as taxable in India because the foreign holding vehicle lacked real commercial substance and genuine business operations. Although the assessee held a Singapore Tax Residency Certificate, the surrounding facts showed it functioned as an interposed conduit within a Chinese-owned group, with no employees, no meaningful office, and no substantiated business activity in Singapore. On that basis, the limitation of benefits clause in Article 24A of the India-Singapore DTAA was applied to deny treaty relief; the TRC alone was not conclusive. en-us Fri, 30 Jan 2026 00:00:00 +0530 Wed, 04 Feb 2026 14:13:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786065 Capital gains on transfer of equity shares and compulsorily convertible debentures were treated as taxable in India because the foreign holding vehicle lacked real commercial substance and genuine business operations. Although the assessee held a Singapore Tax Residency Certificate, the surrounding facts showed it functioned as an interposed conduit within a Chinese-owned group, with no employees, no meaningful office, and no substantiated business activity in Singapore. On that basis, the limitation of benefits clause in Article 24A of the India-Singapore DTAA was applied to deny treaty relief; the TRC alone was not conclusive. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786065