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    <title>2017 (7) TMI 1289 - ITAT MUMBAI</title>
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    <description>Bad debt deduction was treated as distinct from provision for bad and doubtful debts, so the proviso to section 36(1)(vii) did not bar a claim based on actual write-off where double deduction was not involved. Compensation paid to the liquidators of BCCI, with related interest and legal expenses, was regarded as a commercial business outgoing, alternatively a business loss. Amortized lease premium on leasehold property was treated as capital expenditure, while stamp duty on lease acquisition was allowed as lease-related expenditure. Disallowance under section 14A was confined to a reasonable estimate at 1% of exempt income where no interest was attributable to the investments. Foreign branch income was excluded from Indian total income under the applicable DTAA principle for profits attributable to an overseas permanent establishment.</description>
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      <description>Bad debt deduction was treated as distinct from provision for bad and doubtful debts, so the proviso to section 36(1)(vii) did not bar a claim based on actual write-off where double deduction was not involved. Compensation paid to the liquidators of BCCI, with related interest and legal expenses, was regarded as a commercial business outgoing, alternatively a business loss. Amortized lease premium on leasehold property was treated as capital expenditure, while stamp duty on lease acquisition was allowed as lease-related expenditure. Disallowance under section 14A was confined to a reasonable estimate at 1% of exempt income where no interest was attributable to the investments. Foreign branch income was excluded from Indian total income under the applicable DTAA principle for profits attributable to an overseas permanent establishment.</description>
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