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    <title>2023 (9) TMI 435 - ITAT PUNE</title>
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    <description>Capitalised interest that formed part of the investment&#039;s opening value and was not claimed as a revenue deduction could be included in the cost of acquisition of debentures for computing long-term capital gains. On revision, the order under section 263 could not be sustained on the partners&#039; remuneration issue because the original limited scrutiny was confined to the genuineness of capital gains, the remuneration point lay outside that scope, and the underlying tax treatment was debatable with more than one legally sustainable view. The revisional order was therefore set aside and the assessment restored.</description>
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      <link>https://www.taxtmi.com/caselaws?id=442813</link>
      <description>Capitalised interest that formed part of the investment&#039;s opening value and was not claimed as a revenue deduction could be included in the cost of acquisition of debentures for computing long-term capital gains. On revision, the order under section 263 could not be sustained on the partners&#039; remuneration issue because the original limited scrutiny was confined to the genuineness of capital gains, the remuneration point lay outside that scope, and the underlying tax treatment was debatable with more than one legally sustainable view. The revisional order was therefore set aside and the assessment restored.</description>
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