https://www.taxtmi.com/caselaws?id=786065 Taxability of capital gains on sale of equity shares/CCDs by a Singapore incorporated subsidiary was tested against entitlement to India-Singapore DTAA benefits. The tribunal found the entity to be a conduit with no commercial substance or employees, no effective place of management in Singapore, and reliance on a TRC insufficient; consequently the Limitation on Benefits clause applied and treaty benefits were denied. Applying the source rule, the tribunal held the capital gains to be chargeable to tax in India rather than exempt under the DTAA. 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 Taxability of capital gains on sale of equity shares/CCDs by a Singapore incorporated subsidiary was tested against entitlement to India-Singapore DTAA benefits. The tribunal found the entity to be a conduit with no commercial substance or employees, no effective place of management in Singapore, and reliance on a TRC insufficient; consequently the Limitation on Benefits clause applied and treaty benefits were denied. Applying the source rule, the tribunal held the capital gains to be chargeable to tax in India rather than exempt under the DTAA. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786065