Mutual Fund Units Not Classified as Shares Under DTAA with Switzerland; Article 13 (5) (b) Inapplicable.

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....Capital gain – Sale of mutual fund units – DTAA with Switzerland – in the absence of any specific provision under the Act to deem the unit as shares, it could not be considered as shares of companies and, therefore, the provisions of Article 13 (5) (b) cannot be applied in case of units - AT....