https://www.taxtmi.com/caselaws?id=59713 Shipping profits qualify for India-Singapore treaty relief under Article 8 only where the enterprise itself operates ships or aircraft in international traffic as owner, lessee or charterer; participation as a contractual intermediary is insufficient. Article 24 may limit Article 8 relief to income remitted to or received in Singapore where the residence-State taxation condition operates on that basis. Advance-tax interest is not chargeable where the taxpayer held a bona fide non-liability belief supported by a DIT certificate and the income was subject to tax deduction at source. Where Article 8 does not apply, taxability under Article 7 requires examination of permanent establishment and profit attribution. en-us Thu, 26 Jun 2008 00:00:00 +0530 Sun, 10 Dec 2023 18:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59713 Shipping profits qualify for India-Singapore treaty relief under Article 8 only where the enterprise itself operates ships or aircraft in international traffic as owner, lessee or charterer; participation as a contractual intermediary is insufficient. Article 24 may limit Article 8 relief to income remitted to or received in Singapore where the residence-State taxation condition operates on that basis. Advance-tax interest is not chargeable where the taxpayer held a bona fide non-liability belief supported by a DIT certificate and the income was subject to tax deduction at source. Where Article 8 does not apply, taxability under Article 7 requires examination of permanent establishment and profit attribution. Case-Laws Income Tax Thu, 26 Jun 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59713