NR’s capital gains are taxable at concessional rate under Proviso to sec. 112(1); Cairn’s judgment f

IT/ILT: The first and second proviso to section 48 can't be said to be granting the same relief or benefit - Both provisos are neither identical nor they serve the same purpose - Hence, benefit of Proviso to section 112(1) is allowable to non-resident availing of benefit of first proviso to section 48