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    <description>UTI US-64 units were treated as distinct from shares, so profit on their sale was business income and not speculative income capable of set-off against share-trading loss. A further addition based only on a general disclosure under section 132(4) was held unsustainable where income had already been determined on the material on record, and that addition was deleted. Interest under sections 234A, 234B and 234C was consequential but required recomputation after credit for tax deducted at source, while interest under section 220(2) could run only after demand crystallised and the statutory period from notice expired.</description>
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