Where exemption under article 8 of India-Singapore DTAA in terms of which, global income of a tax resident of Singapore from shipping operations, even though earned outside Singapore is taxable only in Singapore on accrual basis. Thus, it was held that article 24 of India-Singapore DTAA could not be invoked to deny benefit of exemption under article even though such income was exempt in Singapore by virtue of separate exemptions provided under Singapore Income-tax Act. (AY. 2015-16)