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    <title>2024 (4) TMI 1411 - ITAT MUMBAI</title>
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    <description>Surplus on redemption of privately placed non-convertible debentures was taxable as income from other sources, not as capital gains, because redemption by the issuer was treated as repayment of debt and the premium was characterised in substance as interest; the assessee, being an intermediate purchaser, was not treated as realising a capital asset gain. The appellate authority was entitled to change the head of income without introducing a new source of income, so that objection failed. As the receipt was not capital gain income, deductions under sections 54F and 54EC were not available. The appeal succeeded only to the limited extent of correcting the taxable surplus to the actual gain on redemption.</description>
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      <title>2024 (4) TMI 1411 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=469395</link>
      <description>Surplus on redemption of privately placed non-convertible debentures was taxable as income from other sources, not as capital gains, because redemption by the issuer was treated as repayment of debt and the premium was characterised in substance as interest; the assessee, being an intermediate purchaser, was not treated as realising a capital asset gain. The appellate authority was entitled to change the head of income without introducing a new source of income, so that objection failed. As the receipt was not capital gain income, deductions under sections 54F and 54EC were not available. The appeal succeeded only to the limited extent of correcting the taxable surplus to the actual gain on redemption.</description>
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