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    <title>2020 (12) TMI 862 - ITAT MUMBAI</title>
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    <description>Resident bank foreign branch income remained includible in Indian total income after section 90(3) and the relevant notification, with relief confined to admissible foreign tax credit on verification. Section 115JB applied to a nationalised bank because the bank was treated as a company under the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970, and the MAT regime was not excluded by the non obstante clause. Foreign branch profits were not excluded from book profit computation, while the adjustment for provision for bad and doubtful debts required limited factual verification. The disallowance under section 14A and the deduction claim for perpetual bond interest were remanded for fresh or de novo consideration.</description>
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      <description>Resident bank foreign branch income remained includible in Indian total income after section 90(3) and the relevant notification, with relief confined to admissible foreign tax credit on verification. Section 115JB applied to a nationalised bank because the bank was treated as a company under the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970, and the MAT regime was not excluded by the non obstante clause. Foreign branch profits were not excluded from book profit computation, while the adjustment for provision for bad and doubtful debts required limited factual verification. The disallowance under section 14A and the deduction claim for perpetual bond interest were remanded for fresh or de novo consideration.</description>
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