Court Rules Global Income Taxable Under Article 13(4) for Pre-2017 Share Sales, Not Covered by Article 13(3A.

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....Taxability of global income - sale of shares - taxability of long term capital gain - Undisputedly, the shares sold by the assessee in the year under consideration were acquired in the year 2009, much prior to 01.04.2017. Therefore, the provisions of Article 13(3A) of the tax treaty would not be applicable. Capital gain derived by the assessee from sale of shares would fall within the ambit of article 13(4) of the tax treaty. - AT....