Separate treatment of capital transactions: DTAA applies per source; s.74 allows carry forward of long-term capital loss

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....ITAT allowed the appeal of the assessee, holding that gains and losses arising from distinct transactions constitute separate sources of income and that treaty application (choice of Act or DTAA) operates qua each source. The Tribunal held that long-term and short-term capital transactions are distinct sources; the DTAA relieved pre-01.04.2017 share gains from Indian taxation while post-01.04.2017 share transactions remained taxable but produced a net long-term capital loss. Applying s.74 of the Act, ITAT directed the AO to permit carry forward of the long-term capital loss to future years and held that dividend income assessed under "income from other sources" cannot be set off against the carried-forward long-term capital loss.....