UAE Resident's Mutual Fund Gains Not Taxable in India Under Article 13(5) of India-UAE DTAA.

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....Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not get covered within the ambit of Article 13(4) of DTAA, but be covered under Article 13(5) - the assessee being a resident of UAE for the purposes of the tax treaty, STCG arising from sale of units should not be liable to tax in India in terms of Article 13(5)....