https://www.taxtmi.com/caselaws?id=773018 Section 70(2) permits set-off of short-term capital loss against short-term capital gains without creating any distinction based on whether securities transaction tax was paid, because the computation provisions govern the set-off mechanism and the rate provisions do not alter it; the assessee's set-off method was therefore accepted. Treaty-exempt grandfathered gains under Article 13(4) of the India-Mauritius DTAA do not enter total-income computation and cannot be reduced by brought forward long-term capital loss under section 90(2); the exemption was therefore allowed in full, with carried-forward losses available only against taxable non-grandfathered gains. en-us Wed, 11 Jun 2025 00:00:00 +0530 Tue, 17 Jun 2025 07:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773018 Section 70(2) permits set-off of short-term capital loss against short-term capital gains without creating any distinction based on whether securities transaction tax was paid, because the computation provisions govern the set-off mechanism and the rate provisions do not alter it; the assessee's set-off method was therefore accepted. Treaty-exempt grandfathered gains under Article 13(4) of the India-Mauritius DTAA do not enter total-income computation and cannot be reduced by brought forward long-term capital loss under section 90(2); the exemption was therefore allowed in full, with carried-forward losses available only against taxable non-grandfathered gains. Case-Laws Income Tax Wed, 11 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773018