Assessees entitled to Article 8 DTAA on ship operational profits; Article 24 inapplicable; tax assessments quashed

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....The HC allowed the special civil applications, held that the appellants-assessee are entitled to the benefit of Article 8 of the India-Singapore DTAA in respect of profits from operation of ships in international traffic at Indian ports, and quashed the Tribunal's order restoring the matter to the Assessing Officer. The Court accepted the certificate dated 09.01.2013 issued by the Singapore tax authority (IRAS) as establishing that such income was taxable in Singapore on an accrual basis; Article 24 of the DTAA was held inapplicable on these facts. Assessment orders are set aside and the tax appeals are allowed in favour of the assessee and against the Revenue.....