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    <title>2019 (3) TMI 1465 - ITAT KOLKATA</title>
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    <description>Unrecorded profit and loss from the same derivative trading activity were treated as arising from one business source, so only the net income was liable to tax and the loss was allowed to be set off against the profit. For section 14A read with Rule 8D, disallowance was confined to investments that actually yielded exempt income, because only expenditure with a proximate nexus to exempt income could be disallowed. STT attributable to derivative trades was linked to taxable trading activity, not exempt dividend income, and was therefore outside section 14A.</description>
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      <link>https://www.taxtmi.com/caselaws?id=377444</link>
      <description>Unrecorded profit and loss from the same derivative trading activity were treated as arising from one business source, so only the net income was liable to tax and the loss was allowed to be set off against the profit. For section 14A read with Rule 8D, disallowance was confined to investments that actually yielded exempt income, because only expenditure with a proximate nexus to exempt income could be disallowed. STT attributable to derivative trades was linked to taxable trading activity, not exempt dividend income, and was therefore outside section 14A.</description>
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      <pubDate>Wed, 27 Mar 2019 00:00:00 +0530</pubDate>
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