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    <title>2022 (10) TMI 1048 - ITAT MUMBAI</title>
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    <description>Income from sale of shares and units was treated as capital gains where the facts showed investment character, so the carried-forward capital loss could be set off only against capital gains and the business-income view was rejected. Deduction under section 57(iii) for interest-related expenditure was allowed only to the extent of the balance claim after excluding the portion linked to tax deduction default. A buyback payment to a Singapore resident shareholder was held not to attract withholding under section 195 on the treaty position and the timing of the payment, so disallowance under section 40(a)(ia) was deleted.</description>
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