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Case Law Details

Case Name : Variable Insurance Products Fund Vs DIT (ITAT Mumbai)
Related Assessment Year : 2006-07
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S. 271(1)(c); in favor of taxpayer : The taxpayer was a trust organized in the US and was a resident of the US. As regards India, it was registered with SEBI as a sub- account of M/s Fidelity Management Resources Co. It filed a return of income declaring short-term capital gains and dividend income.  Thereafter, based on an AAR ruling in case of XZY/ABC Equity  Fund (2005) (250 ITR 194), the taxpayer filed a revised return of income,

wherein it claimed that the fund was carrying on business  as an investment trust and the s

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