In the result, the appeal of the assessee is allowed
Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2018-19 Reverse Age Health Dcit Services Pte Ltd. Vs Circle – 3 (1) (1) 31, Tanglin Road, 03-04, St. International Taxation Regis Residences, New Delhi Singapore- 247912 Pan No.Aaicr9878A (Appellant) (Respondent) Appellant By Sh. Deepak Chopra, Advocate Respondent By Sh. Sanjay Kumar, Sr. Dr Date Of Hearing: 13/02/2023 Date Of Pronouncement: 17/02/2023
24A(1) of the India- Singapore DTAA) and, therefore, short term capital gain of Rs.1,92,63,473/- was held to be taxable in India in the hands of the assessee. 7. In taking this action against the assessee the AO and the DRP have ignored completely the tax residency certificate of the assessee issued by Singapore Tax Authority