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    <title>2012 (10) TMI 1063 - ITAT MADRAS</title>
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    <description>Double taxation relief for Bangkok branch income under the India-Thailand DTAA was applied through the tax credit method under Article 23(3), so the Revenue&#039;s approach was upheld. The claim for interest under section 244A required verification of the computation basis and was remitted for fresh consideration. For bad debts and provision for bad and doubtful debts, the distinction between rural and non-rural advances was maintained; non-rural bad debts were treated as allowable in full, while rural advances had to be computed with reference to the relevant provision account under section 36(1)(viia). Loss on revaluation of investments remained allowable where banks consistently valued securities at cost or market value, whichever was lower.</description>
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      <description>Double taxation relief for Bangkok branch income under the India-Thailand DTAA was applied through the tax credit method under Article 23(3), so the Revenue&#039;s approach was upheld. The claim for interest under section 244A required verification of the computation basis and was remitted for fresh consideration. For bad debts and provision for bad and doubtful debts, the distinction between rural and non-rural advances was maintained; non-rural bad debts were treated as allowable in full, while rural advances had to be computed with reference to the relevant provision account under section 36(1)(viia). Loss on revaluation of investments remained allowable where banks consistently valued securities at cost or market value, whichever was lower.</description>
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