https://www.taxtmi.com/caselaws?id=791748 Section 90(2) permits transaction-wise application of the Income-tax Act, 1961 and the applicable DTAA where each is more beneficial. For distinct share transactions in the same year, treaty-exempt capital gains on shares acquired before 01.04.2017 under Article 13(4A) of the India-Singapore DTAA could be claimed under the treaty, while capital losses on other transactions could still be carried forward or set off under the Act. The common head of capital gains did not merge separate sources of income, and treaty-exempt gains could not be forced back into domestic computation merely to absorb losses from other distinct transactions. en-us Mon, 11 May 2026 00:00:00 +0530 Sat, 16 May 2026 09:09:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791748 Section 90(2) permits transaction-wise application of the Income-tax Act, 1961 and the applicable DTAA where each is more beneficial. For distinct share transactions in the same year, treaty-exempt capital gains on shares acquired before 01.04.2017 under Article 13(4A) of the India-Singapore DTAA could be claimed under the treaty, while capital losses on other transactions could still be carried forward or set off under the Act. The common head of capital gains did not merge separate sources of income, and treaty-exempt gains could not be forced back into domestic computation merely to absorb losses from other distinct transactions. Case-Laws Income Tax Mon, 11 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791748