Article 13(4) of DTAA benefit is available on entire STCG/ LTCG before setting off brought forward STCG/LTCG

DCIT Vs Swiss Finance Corporation (ITAT Mumbai)

ITAT Mumbai held that assessee is entitled to claim benefit of Article 13(4) of DTAA in respect of entire current year Short/Long Term Capital Gains, without setting of the Brought Forward Short/Long Term Capital Gains.

Facts-

The Assessee is a non-resident Foreign Institutional Investor (FII) registered as a company in Mauritius. During the assessment proceeding, AO noted that the Assessee

Please become a Premium member. If you are already a Premium member, login here to access the full content.