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    <title>2012 (4) TMI 50 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Consideration received for release and relinquishment of tenancy rights was treated as gains arising from alienation of immovable property, and because the property was situated in India, the amount was taxable in India under the treaty. Capital gains on sale of unquoted shares of a closely held company were also taxable in India where the share value was derived principally from immovable property in India; the treaty provision for property-linked share transfers applied. Tax deducted at source was allowed as credit on proper verification.</description>
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      <description>Consideration received for release and relinquishment of tenancy rights was treated as gains arising from alienation of immovable property, and because the property was situated in India, the amount was taxable in India under the treaty. Capital gains on sale of unquoted shares of a closely held company were also taxable in India where the share value was derived principally from immovable property in India; the treaty provision for property-linked share transfers applied. Tax deducted at source was allowed as credit on proper verification.</description>
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