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    <title>2013 (9) TMI 364 - ITAT MUMBAI</title>
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    <description>Interest on a nostro account was treated as taxable, and section 14A disallowance was deleted because that provision applies only to income exempt from total income. Exemption under section 10(15) was stated to apply to gross interest from tax-free securities, and no further disallowance under section 14A was sustained where sufficient interest-free funds existed. Interest and commission received by an Indian permanent establishment from its head office and overseas branches were regarded as non-taxable on the mutuality principle, with corresponding deduction for related outgo also denied. Interest under section 244A was considered taxable in the year of receipt, subject to treaty-rate examination under the applicable India-France agreement.</description>
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      <title>2013 (9) TMI 364 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=236932</link>
      <description>Interest on a nostro account was treated as taxable, and section 14A disallowance was deleted because that provision applies only to income exempt from total income. Exemption under section 10(15) was stated to apply to gross interest from tax-free securities, and no further disallowance under section 14A was sustained where sufficient interest-free funds existed. Interest and commission received by an Indian permanent establishment from its head office and overseas branches were regarded as non-taxable on the mutuality principle, with corresponding deduction for related outgo also denied. Interest under section 244A was considered taxable in the year of receipt, subject to treaty-rate examination under the applicable India-France agreement.</description>
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