https://www.taxtmi.com/caselaws?id=772280 For a Singapore resident, pre-amended Article 13(4) of the India-Singapore DTAA allocated taxing rights over gains from alienation of shares of Indian companies exclusively to Singapore for transactions in previous year 2015-16, so the gains were not taxable in India. Article 24(1) could not defeat that allocation because Article 13(4) is a taxing-allocation rule, and the record did not establish remittance-basis taxation in Singapore. Separately, short-term capital losses were treated as distinct from the treaty-protected gains and were allowed to be carried forward under the Act without set-off against those gains. en-us Thu, 29 May 2025 00:00:00 +0530 Fri, 15 May 2026 10:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772280 For a Singapore resident, pre-amended Article 13(4) of the India-Singapore DTAA allocated taxing rights over gains from alienation of shares of Indian companies exclusively to Singapore for transactions in previous year 2015-16, so the gains were not taxable in India. Article 24(1) could not defeat that allocation because Article 13(4) is a taxing-allocation rule, and the record did not establish remittance-basis taxation in Singapore. Separately, short-term capital losses were treated as distinct from the treaty-protected gains and were allowed to be carried forward under the Act without set-off against those gains. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772280