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    <title>2018 (9) TMI 215 - ITAT MUMBAI</title>
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    <description>Gain from early settlement or cancellation of forward foreign exchange contracts was treated as capital gains, not income from other sources, because the assessee&#039;s own earlier years had already characterised the receipt as capital in nature and that consistent treatment was followed. The Tribunal also held that treaty relief under Article 13(4) of the India-Singapore DTAA could not be denied by invoking Article 24, as the limitation relied on by the Revenue was not accepted on these facts. The lower appellate view was therefore sustained, the Revenue&#039;s appeals failed, and the assessee&#039;s remaining grounds did not survive.</description>
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      <title>2018 (9) TMI 215 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=366479</link>
      <description>Gain from early settlement or cancellation of forward foreign exchange contracts was treated as capital gains, not income from other sources, because the assessee&#039;s own earlier years had already characterised the receipt as capital in nature and that consistent treatment was followed. The Tribunal also held that treaty relief under Article 13(4) of the India-Singapore DTAA could not be denied by invoking Article 24, as the limitation relied on by the Revenue was not accepted on these facts. The lower appellate view was therefore sustained, the Revenue&#039;s appeals failed, and the assessee&#039;s remaining grounds did not survive.</description>
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