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Jan 03, 2026
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NRI woman earns Rs 1.35 crore from mutual funds, pays zero tax in India, gets income tax notice: How India-Singapore DTAA saved her
A Mumbai-based woman who is a tax resident of Singapore, sold some of her debt and equity mutual fund investments in India and claimed tax exemption on capital gains under Article 13 of the India-Singapore Double Taxation Avoidance Agreement (DTAA). However, the tax department rejected her claim.
Thus she challenged the denial before the Dispute Resolution Panel (DRP) which also ruled against her. The taxpayer then approached the Income Tax Appellate Tribunal (ITAT) Mumbai, arguing that in a comparable case under the India- UAE (United Arab Emirates) DTAA, ITAT Cochin had granted capital gains relief to an Indian resident of UAE and the same priciple should also apply to her case.
Accepting her argument, ITAT Mumbai examined the India-Singapore DTAA in detail and ruled in her favour, granting the capital gains exemption. The taxpayer was represented before ITAT Mumbai by Dr. K Shivaram and Mr. - Rahul Hakani.
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