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    <description>A company registered with the RBI as a non-banking financial company, and whose principal business was granting loans and advances, was held outside the scope of the Explanation to Section 73 of the Income-tax Act. The share-trading loss was therefore not treated as speculation loss, because the deeming fiction in that provision had to be strictly construed on the facts found. The loss was allowed to be set off against business income, and the Revenue&#039;s reliance on other authorities was rejected as factually distinguishable.</description>
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