S. 45: Capital gains–Rights entitlement-Capital gains arising on sale of rights entitlements are not equity shares as s. 62 of Companies Act, 2013-rights entitlement are covered under the provisions of art. 13(6) and, therefore, cannot be subjected to tax in India but is taxable in the resident State of the assessee i.e., Ireland-DTAA-India-Ireland. [S.90, Art. 13(6), Companies Act, 2013, S.62,]