Avoidance of tax by sale and buy-back transactions: interest treated as income when such transactions shift beneficial ownership. Clause 120 treats interest from a security as part of a person's total income where the person undertakes a sale-and-buy-back transaction, the interest accrues to another as a result of that transaction, and the income would have been includible in the person's total income had the transfer not occurred.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Avoidance of tax by sale and buy-back transactions: interest treated as income when such transactions shift beneficial ownership.
Clause 120 treats interest from a security as part of a person's total income where the person undertakes a sale-and-buy-back transaction, the interest accrues to another as a result of that transaction, and the income would have been includible in the person's total income had the transfer not occurred.
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