Bombay High Court recently issued an order on whether a certificate issued by the Singapore Tax Authorities certifying that capital gains income is taxed in Singapore is sufficient evidence for accepting a claim for relief under the 1994 India-Singapore tax treaty. The case involved Citicorp Investment Bank (Singapore) Ltd. (the assessee), which is a tax resident of Singapore. In assessment year 2010-2011, the assessee declared capital gains of INR 866,263,158 on the sale of debt instruments and claimed an exemption under paragraph 4 of Article 13 (Capital Gains) of the India-Singapore tax treaty. The assessing officer (AO) challenged the claim,...