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    <description>Compensation received under a settlement must be characterised by its true source and substance: the share-linked component retained the character of capital gains but was exempt under the Indo-French DTAA, the land-linked amount was taxable as short-term capital gain, and the balance compensation for fraud, misappropriation and breach of trust was a capital receipt not chargeable to tax as income from other sources. For a non-resident assessee whose income was subject to tax deduction at source, interest under section 234B was not leviable because the advance-tax liability did not arise in the manner contended by the Revenue.</description>
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