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    <title>2021 (12) TMI 1313 - ITAT BANGALORE</title>
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    <description>Payments for NPCI NFS ATM charges were treated as a common banking facility rather than specialised technical service, so section 194J did not apply and the related section 40(a)(ia) disallowance was deleted. Bad debts written off by debiting the profit and loss account and reducing the corresponding advances were held allowable under section 36(1)(vii), without any need to close each borrower account individually. Depreciation on HTM securities was also disallowed by the Revenue unsuccessfully, following the settled banking treatment of such investments. The section 14A and section 115JB issues were sent back for fresh examination in light of the governing legal position and incomplete earlier consideration.</description>
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      <link>https://www.taxtmi.com/caselaws?id=301173</link>
      <description>Payments for NPCI NFS ATM charges were treated as a common banking facility rather than specialised technical service, so section 194J did not apply and the related section 40(a)(ia) disallowance was deleted. Bad debts written off by debiting the profit and loss account and reducing the corresponding advances were held allowable under section 36(1)(vii), without any need to close each borrower account individually. Depreciation on HTM securities was also disallowed by the Revenue unsuccessfully, following the settled banking treatment of such investments. The section 14A and section 115JB issues were sent back for fresh examination in light of the governing legal position and incomplete earlier consideration.</description>
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