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    <title>2020 (6) TMI 471 - ITAT KOLKATA</title>
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    <description>Short deduction of tax did not justify disallowance under section 40(a)(ia), because the provision was treated as applying to non-deduction rather than a mere shortfall. For a banking company, the Tribunal also held that the section 14A read with Rule 8D disallowance could not be sustained in the circumstances. It further followed its earlier view that section 115JB did not apply to the assessee bank for the relevant year. Income from immovable property in Singapore was held to fall under Article 6 of the India-Singapore treaty and not to be taxed in India as claimed by the Revenue. The Revenue&#039;s objections failed and the relief granted below was sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=396096</link>
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