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Exempt tax-free bond interest was not met with proportional disallowance where the bonds were earlier-year investments and sufficient own interest-free funds were available; the deletion of disallowance was sustained. Broken period interest on securities held as stock-in-trade was allowed as revenue expenditure. Foreign-currency loan interest from Indian borrowers was taxable on gross basis under the concessional regime. Interest between a foreign bank's head office and Indian branch was treated as self-dealing, so no taxable income or deductible expense arose. Section 14A did not apply to mutuality receipts, SLR default interest was compensatory and deductible, and a fresh expatriate salary claim was not admitted for want of foundational facts. The book-profit issue for standard assets became academic because MAT was held inapplicable to a banking company; interest on overseas placements was remanded only on actual accrual.
Exempt tax-free bond interest was not met with proportional disallowance where the bonds were earlier-year investments and sufficient own interest-free funds were available; the deletion of disallowance was sustained. Broken period interest on securities held as stock-in-trade was allowed as revenue expenditure. Foreign-currency loan interest from Indian borrowers was taxable on gross basis under the concessional regime. Interest between a foreign bank's head office and Indian branch was treated as self-dealing, so no taxable income or deductible expense arose. Section 14A did not apply to mutuality receipts, SLR default interest was compensatory and deductible, and a fresh expatriate salary claim was not admitted for want of foundational facts. The book-profit issue for standard assets became academic because MAT was held inapplicable to a banking company; interest on overseas placements was remanded only on actual accrual.
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