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of <h1>Securities Transactions Scrutinized: Tax Authorities Empowered to Prevent Income Shifting and Manipulation Under Section 94</h1> Section 94 of the Income Tax Act addresses tax avoidance through securities transactions. It prevents taxpayers from manipulating income recognition by selling and repurchasing securities or transferring beneficial interests. The provision allows tax authorities to treat interest or dividend income as belonging to the original owner if transactions are designed to shift income. Taxpayers can avoid application by proving no systematic tax avoidance. The section also includes specific rules about loss calculations related to securities transactions around dividend record dates.
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