Carried forward losses cannot be set-off against exempt capital gains under DTAA

TVF Fund Ltd Vs DCIT, International Taxation (ITAT Mumbai)  The case of TVF Fund Ltd vs. DCIT before ITAT Mumbai pertains to the assessment year 2021-22, challenging the final assessment order issued by the Deputy Commissioner of Income Tax (International Taxation). The appellant, TVF Fund Ltd, raised multiple objections primarily concerning the applicability of tax provisions under the Income Tax Act, 1961, and the Double Taxation Avoidance Agreement (DTAA) between India and Mauritius. The key contention was whether capital losses incurred in previous years should be allowed to be carried f...