Dismissing the appeal of the Revenue the Court held that   the property alienated was debt instruments and the income would come under article 13(4) of the Double Taxation Avoidance Agreement according to which gains from alienation of any property be taxable only in Singapore, of which the alienator (the assessee) was a resident. Therefore, the entire capital gains was taxable in Singapore. The exemption or reduction of tax to be allowed under the Double Taxation Avoidance Agreement in India shall only apply to so much of the income as is remitted to or received in Singapore where the laws in force in Singapore provides that such income is subject to tax by reference to the amount which is remitted or received in Singapore. When 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, article 24(1) would not apply. The certificate issued by the Singapore tax authorities would constitute sufficient evidence for accepting the legal position. No questions of law arose. (AY.2010-11)