New Double Taxation Agreement's Article 13(4) Doesn't Apply Retroactively to Capital Gains in India.

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....Income accrued in India - Capital gain - the new double taxation avoidance agreement has come into force much letter then the transaction took the place. In the new double taxation, avoidance agreement there is a provision as per article 13 (4) wherein now such transaction, probably is chargeable to tax in India. However, as the amended double taxation avoidance agreement is subsequent to the date of transaction it does not apply.....