Thursday, 15 October 2015

LOB clause of Indo-Singapore DTAA won't apply if income of Singaporean Shipping Co. is remitted in U

IT/ILT : Where appellant Indian company filed return in respect of a ship which was owned by a Singapore company, and Inland Revenue Authority of Singapore confirmed that in case of Singapore company, freight income has been regarded as Singapore sourced income and brought to tax on an accrual basis (and not remittance basis), entire freight income which was only from operation of ships in international traffic, was taxable only in Singapore; same could not be brought to tax in India

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