Bombay HC allows benefit of Article 13(4) of India Singapore DTAA on capital gains and rejects Revenue’s contention on application of Article 24 (Limitation of Relief)
Citicorp Investment Bank ( S ingapore) Ltd. 1 (‘ is a tax resident of Singapore. It is registered as Foreign Institutional Investor in debt segment with SEBI. For the FY 2009 10 (AY 2010 11), the assessee had earned capital gains on sale of debt securities in India on which it had claimed the benefit of Article 13(4) of the India Singapore DTAA (‘DTAA’).
