GAAR and Rule 10U: Treaty Benefits Upheld for Short-Term Capital Gains Below Threshold, Shares Acquired Before Cut-Off Date.

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....Supremacy of law - GAAR - in the case in hand the short term capital gain the tax on which is below the threshold set out in Rule 10 U (1) (a) (supra) further the impugned shares were acquired by the assessee on 22.08.2016 which is prior to the cut off date set out in Rule 10 U (1)(d) - Assuming domestic GAAR provision are applicable but for the aforestated facts the treaty benefit cannot be denied to the assessee. - AT....