https://www.taxtmi.com/caselaws?id=771598 Rights entitlements were treated as a distinct asset from shares for India-Ireland DTAA purposes, so gains from their transfer fell under the residuary residence-based provision and were not taxable in India. The note also states that, in the absence of any statutory sequence for capital gains set-off, short-term capital loss on STT-paid shares could be set off against short-term capital gain on non-STT-paid shares in the manner more beneficial to the assessee. TDS credit and refund-related matters were left to be examined by the Assessing Officer through rectification proceedings in accordance with law. en-us Fri, 23 May 2025 00:00:00 +0530 Wed, 28 May 2025 08:26:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771598 Rights entitlements were treated as a distinct asset from shares for India-Ireland DTAA purposes, so gains from their transfer fell under the residuary residence-based provision and were not taxable in India. The note also states that, in the absence of any statutory sequence for capital gains set-off, short-term capital loss on STT-paid shares could be set off against short-term capital gain on non-STT-paid shares in the manner more beneficial to the assessee. TDS credit and refund-related matters were left to be examined by the Assessing Officer through rectification proceedings in accordance with law. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771598