Benefits under Indo-Singapore tax treaty cannot be denied where such income have taxed on accrual basis in treaty country

ITAT Rajkot held In the case of GAC Shipping India Pvt. Ltd. vs. ITO – International Taxation that entire freight income of the assessee, which is only from operation of ships in international traffic, is taxable only in Singapore.

It was held that in order to come out of the mischief of Article 24, the onus is on the assessee is to show that the amount is remitted to, or received in Singapore, but then such an onus is confined to

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