Held that   that J had issued a certificate specifically confirming the fact that it had considered the income  on accrual basis earned on the vessel in question during its voyage from September 28, 2016 to October 27, 2016 while it was in international traffic and passed through Indian waters and accordingly the assessee had offered its taxes to the Singapore Revenue authorities. The certificate of the Singapore Revenue authorities issued on December 10, 2016 clearly mentioned that the assessee had discharged estimated tax as per the original assessment dated March 29, 2016. The Double Taxation Avoidance Agreement between India and Singapore was applicable as the assessee had already paid taxes for the international voyage of vessel MV for the period September 28, 2016 to October 27, 2016 while it was in international traffic, which included the voyage from one Indian port to another Indian port. The stand of the Revenue that the assessee had not paid the taxes in Singapore was incorrect, and in fact, it was not just a coastal run but a part of an international voyage. Therefore, articlesandof Double Taxation Avoidance Agreement between India and Singapore were applicable.(AY.2017-18)