Tax on income of Foreign Institutional Investors from securities or capital gains arising from their transfer.

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....ble on total income of an assessee, being a specified fund or Foreign Institutional Investor, which includes income^[1] referred to in column B of the Table below, shall be the aggregate of the amounts mentioned in column C thereof. Table Sl.No. Income Income-tax payable A B C 1. Income, in respect of securities^[2] other than units referred to in section 208. (a) 20 ....

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.... provisions of this section shall apply only to the extent of income that is attributable to units held by non-resident (not being a permanent establishment of such non-resident in India) calculated in the manner as prescribed, irrespective of the provisions of sub-section (1). (3) Irrespective of anything contained in sub-section (1), where the specified fund-- (a) is investment divis....

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....by the amount of such income; and (ii) the deduction under Chapter VIII shall be allowed as if the gross total income as so reduced, were the gross total income of the specified fund or Foreign Institutional Investor. (5) The provisions of section 72(6) shall not apply for the computation of capital gains arising out of the transfer of securities referred to in sub-section (1) (Table: ....