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    <title>2017 (4) TMI 121 - ITAT AHMEDABAD</title>
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    <description>Portfolio management expenses and interest charges incurred for safekeeping and administration of foreign securities were held deductible under section 57(iii) because they had a clear nexus with dividend and interest income, and the supporting documentation was accepted; the disallowance was deleted. Relief by way of foreign tax credit on U.S. tax withheld from dividend income was not finally determined because treaty entitlement depended on verification of residential status, the character of income, actual withholding, and treaty limits; the matter was remitted to the Assessing Officer for fresh examination and a speaking order after hearing the assessee.</description>
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    <pubDate>Wed, 29 Mar 2017 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=341151</link>
      <description>Portfolio management expenses and interest charges incurred for safekeeping and administration of foreign securities were held deductible under section 57(iii) because they had a clear nexus with dividend and interest income, and the supporting documentation was accepted; the disallowance was deleted. Relief by way of foreign tax credit on U.S. tax withheld from dividend income was not finally determined because treaty entitlement depended on verification of residential status, the character of income, actual withholding, and treaty limits; the matter was remitted to the Assessing Officer for fresh examination and a speaking order after hearing the assessee.</description>
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