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Section 57(iii) deduction requires expenditure to be laid out wholly and exclusively for earning the relevant income, and the Tribunal allowed only proportionate interest linked to the loan traceable to the advance, while disallowing the balance for lack of direct nexus. Transfer of dematerialised shares from the assessee's demat account to his mother's account was treated as a transfer of a capital asset, so capital gains computed on a deemed consideration basis were sustained. The Tribunal also upheld admission of an alternative section 54F claim for examination in appeal and permitted set-off of F&O loss under the loss-set-off provisions despite the claim not being raised in the return.
Section 57(iii) deduction requires expenditure to be laid out wholly and exclusively for earning the relevant income, and the Tribunal allowed only proportionate interest linked to the loan traceable to the advance, while disallowing the balance for lack of direct nexus. Transfer of dematerialised shares from the assessee's demat account to his mother's account was treated as a transfer of a capital asset, so capital gains computed on a deemed consideration basis were sustained. The Tribunal also upheld admission of an alternative section 54F claim for examination in appeal and permitted set-off of F&O loss under the loss-set-off provisions despite the claim not being raised in the return.
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