Foreign institutional investor capital gains from specified securities qualify for no tax deduction when all prescribed conditions are met.

Income payable to a Foreign Institutional Investor from specified securities is ordinarily subject to tax deduction at source. No deduction is required where the income is capital gains arising from transfer of the specified securities. The non-deduction treatment applies only when the income is capital gains, the gains arise from transfer of the specified securities, and the recipient is a Foreign Institutional Investor. Income that does not satisfy these cumulative conditions remains subject to the ordinary withholding requirement.

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