All conditions of paragraph 4.2 of Article 24 of DTAA needs to be satisfied simultaneously

ADIT (IT) 3(1) Vs Global Cricket Corporation Pte Ltd. (ITAT Mumbai)

ITAT Mumbai held that provisions of Article 24 of DTAA between India and Singapore will be applicable only when condition no. 1, condition no. 2 and condition no. 3 in paragraph 4.2 are satisfied simultaneously. Here, as condition no. 1 is not satisfied, DTAA would not be attracted in case of GCC.

Facts- AO had denied the benefit of DTAA to GCC by holding that provisions of Article 24 of DTAA are attracted

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