Article 24 — the law in short
What the courts have decided on section Article 24, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.
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M/s Atlantic Shipping Pvt Ltd v ITO (International Taxation)
High CourtHelps taxpayerValidity unconfirmed
Our principal's freight was exempt under Article 8, but the officer says Article 24 applies because the freight went to a London account. Who wins?
The shipowner wins on these facts. The Gujarat High Court held that the assessee is entitled to the benefit of Article 8 of the India-Singapore treaty and that Article 24, the limitation of relief clause, does not apply, quashing the Tribunal's direction to send the matter back to the Assessing Officer to verify the Singapore tax authority's certificate.
Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.