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of ITAT determined that for transactions of share alienation during FY 2015-16, pre-amended India-Singapore DTAA provisions apply. The tribunal found insufficient evidence regarding Singapore tax treatment, leaving the second condition of Article 24(1) unresolved. Ultimately, the assessee was deemed eligible for Article 13(4) benefits, with taxing rights attributed to Singapore for capital gains on shares acquired before 01 April 2017. The tribunal directed the Assessing Officer to allow carry forward of short-term capital losses and apply treaty benefits for gross short-term capital gains, effectively allowing the additional ground of appeal.
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