Singapore Entity can carry forward short-term capital losses

Goldman Sachs India Investments (Singapore) PTE Limited Vs DCIT (ITAT Mumbai)

1. Section 90(2) of Income Tax Act provides that where the Central Government has entered into an agreement with the Government of any country outside India for granting relief of tax (Double Taxation Avoidance Agreement or DTAA) then, the provisions of the Act shall apply to the extent, they are more beneficial to the assessee.

2. Under section 74 , if capital loss cannot be wholly set off, the amount of loss no

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