Court held that under the laws in force in Singapore, the income is subject to tax by reference to the full amount thereof, whether or not remitted to or received in Singapore, then in that case art. 24(1) would not apply. Certificate issued by Singapore Tax authorities will constitute sufficient evidence for accepting the legal position. Tribunal was justified in allowing benefit of art. 8 and in holding that the limitation of benefit provided under art. 24 would not be applicable. No substantial question of law arises.(AY. 2008-09,  2012-13)