https://www.taxtmi.com/caselaws?id=767561 ITAT Mumbai ruled in favor of the assessee regarding taxation of short-term capital gains on sale of rights entitlement under India-Ireland DTAA. The tribunal held that rights entitlements are separate assets distinct from shares and fall under Article 13(6), making gains taxable only in Ireland, not India. Capital losses under Article 13(5) cannot be set off against gains from rights entitlement sales as they are not subject to Indian taxation. The tribunal directed the AO to consider the assessee's rectification application regarding computational errors in the assessment order. en-us Wed, 19 Mar 2025 00:00:00 +0530 Thu, 20 Mar 2025 18:35:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767561 ITAT Mumbai ruled in favor of the assessee regarding taxation of short-term capital gains on sale of rights entitlement under India-Ireland DTAA. The tribunal held that rights entitlements are separate assets distinct from shares and fall under Article 13(6), making gains taxable only in Ireland, not India. Capital losses under Article 13(5) cannot be set off against gains from rights entitlement sales as they are not subject to Indian taxation. The tribunal directed the AO to consider the assessee's rectification application regarding computational errors in the assessment order. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767561