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    <title>2022 (12) TMI 738 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai ruled in favor of non-resident assessees in a tax dispute regarding interest income accrued in a foreign bank account. The court held that since the assessees were non-residents and the interest income actually accrued outside India, it was not taxable in India. The ITAT emphasized the strict interpretation of deeming provisions under the Income Tax Act and concluded that the interest income did not meet the criteria to be deemed to accrue in India. As a result, the decision of the CIT(A) was upheld, and all appeals filed by the Revenue were dismissed.</description>
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    <pubDate>Thu, 20 Oct 2022 00:00:00 +0530</pubDate>
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      <title>2022 (12) TMI 738 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=431621</link>
      <description>The ITAT Mumbai ruled in favor of non-resident assessees in a tax dispute regarding interest income accrued in a foreign bank account. The court held that since the assessees were non-residents and the interest income actually accrued outside India, it was not taxable in India. The ITAT emphasized the strict interpretation of deeming provisions under the Income Tax Act and concluded that the interest income did not meet the criteria to be deemed to accrue in India. As a result, the decision of the CIT(A) was upheld, and all appeals filed by the Revenue were dismissed.</description>
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      <pubDate>Thu, 20 Oct 2022 00:00:00 +0530</pubDate>
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