Corporate tax alert

Limitation of relief article not applicable if income is subject to tax in Singapore on full amount

The Bombay High Court has rendered its decision that, based on facts, the taxpayer, a Singaporean tax resident, was entitled to the benefit of Article 13(4) of the India-Singapore tax treaty [relating to capital gains] in respect of its capital gains from sale of Indian securities and that the provisions of Article 24 of the India-Singapore tax treaty [relating to limitation of relief] did not apply. 

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