Held that Long-term capital gains earned on the sale of shares by the assessee Singapore based company, cannot be taxed in India in view of art. 13 of the India-Singapore DTAA and, therefore, assessee is eligible to carry forward the long-term capital loss under the provisions of the Act. Issue as to whether the long-term capital loss is to be allowed to be carried forward as per the Act or to be set off against the LTCG which is eligible for exemption under the DTAA is a debatable issue and, therefore, the AO was not correct in making the disallowance of carry forward of long-term capital loss by way of prima facie adjustment under s. 143(1).(AY. 2020-21)