Assessee, an Indian company, acted as shipping agent for a Singapore-resident enterprise (ST Shipping) engaged in operating owned/chartered ships in international waters. During relevant year, ST Shipping’s ships performed voyages from Indian ports, and assessee filed vessel voyage returns under section 172(3), declaring Nil income in India by claiming exemption under Article 8 of the India-Singapore DTAA. Assessing Officer invoked Article 24 (Limitation of Relief), denied Article 8 exemption, and held assessee liable to tax under section 172 on the ground that freight amounts were remitted to a bank account in London, not to Singapore. Assessee tendered a certificate issued by the Inland Revenue Authority of Singapore (IRAS) asserting non-applicability of Article 24. Tribunal restored the matter to the Assessing Officer to verify the contents of said certificate. On appeal the Court held that    Tribunal could not have restored matter back to Assessing Officer only on mere suspicion and doubts contrary to findings arrived at by High Court regarding same certificate issued by IRAS, Tribunal ought not to have further deliberated upon contents of certificate which was already held to be applicable in facts of case in absence of any other material on record to demonstrate that veracity of certificate issued by IRAS was doubtful. Therefore, the benefit of Article 8 of DTAA to profits derived from the operation of ships in international traffic at Indian ports would be governed by Article 8, and not Article 24 and the matter could not have been restored to the Assessing Officer to give a second inning to the Revenue to verify the certificate issued way back in 2013.  Assessment order passed by the Assessing Officer after the order of remand was rendered infructuous.  (AY. 2012-13)