'Limitation on benefit' clause denies treaty benefit for non-remittance of interest to Singapore

IT/ILT : Tax refund received by a Singaporean resident won't be taxed at concessional rate of 15% under article 11 of India-Singapore DTAA, as mere proving that it was not deposited in bank account in India won't be sufficient to prove its receipt in or remittance to Singapore to satisfy limitation of benefit clause