Assessee, a company incorporated in Singapore, is  engaged in business of operating ships in international traffic and earned freight income from such shipping operations with India.  The Assessing Officer held  that freight income was transferred to account of agents of assessee who were resident of Denmark.  He t held that assessee would not qualify for tax exemption under article 8 in view of article 24 on ground that assessee was not subject to tax in Singapore as freight income was not directly remitted to Singapore and assessee was liable to be taxed in India. On appeal the Tribunal held that  since shipping income was taxable in Singapore, on an arising basis when income was earned by shipping enterprise regardless of whether shipping income was received in or remitted to Singapore, clause (1) of article 24 of Indo-Singapore DTAA would not apply to deny benefit of article 8 of Indo-Singapore DTAA to said company. (AY. 2017-18)