The Assessing Officer adjusted the assessee’s short-term capital loss against the gain arising from the sale of rights entitlements before granting treaty relief. The Tribunal held that since gains from rights entitlements were not chargeable to tax in India under Article 13(6) of the DTAA, such gains did not enter the computation of taxable income in India. Consequently, the short-term capital loss governed by the domestic provisions could not be adjusted against such exempt gains. (AY. 2021-22).