https://www.taxtmi.com/caselaws?id=771598 Rights entitlements are distinct assets from shares for India-Ireland treaty purposes. Gains from their transfer, where not covered by the specific capital-gains provisions for shares or other property, fall under the residuary provision allocating taxation to the residence State, rather than India. Short-term capital losses on STT-paid shares may be set off against short-term gains on non-STT-paid shares using the taxpayer's more beneficial sequence where no statutory set-off chronology prohibits it. TDS credit and refund discrepancies require examination through rectification after a reasonable opportunity of hearing. 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 are distinct assets from shares for India-Ireland treaty purposes. Gains from their transfer, where not covered by the specific capital-gains provisions for shares or other property, fall under the residuary provision allocating taxation to the residence State, rather than India. Short-term capital losses on STT-paid shares may be set off against short-term gains on non-STT-paid shares using the taxpayer's more beneficial sequence where no statutory set-off chronology prohibits it. TDS credit and refund discrepancies require examination through rectification after a reasonable opportunity of hearing. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771598