Rights Entitlement Deemed Transferable Asset: Capital Gains Taxation Resolved Under India-Saudi Arabia Double Taxation Avoidance Agreement

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....ITAT adjudicated a dispute concerning capital gains taxation on rights entitlement under India-Saudi Arabia DTAA. The tribunal determined that rights entitlement constitutes a separate and distinct right capable of independent transfer. Consequently, short-term capital gains from rights entitlement sale are taxable exclusively in the resident state (Saudi Arabia) per Article 13(6) of the bilateral tax treaty. The tribunal deleted the contested addition related to capital gains and directed the Assessing Officer to review and grant appropriate advance tax credit after necessary verification, allowing the assessee's appeal for statistical purposes.....