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    <title>2022 (6) TMI 1428 - MADRAS HIGH COURT</title>
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    <description>A statutory transfer of profits to a reserve fund under the RBI Act was treated as an application of income after accrual, not diversion at source, and was not deductible in normal computation or book profit under section 115JB. Bad debts were allowable where actually written off in the income-tax books, even if only provided for in corporate accounts. Royalty for a non-exclusive, non-transferable trademark licence, ESOP expense, loss on investments treated as stock-in-trade, and foreign exchange hedging loss were each accepted as revenue or business deductions on the facts. Section 14A read with Rule 8D required proper recorded dissatisfaction and was remanded where the factual basis was incomplete. Interest under section 234D and disallowance under section 40(a)(ia) were upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=309802</link>
      <description>A statutory transfer of profits to a reserve fund under the RBI Act was treated as an application of income after accrual, not diversion at source, and was not deductible in normal computation or book profit under section 115JB. Bad debts were allowable where actually written off in the income-tax books, even if only provided for in corporate accounts. Royalty for a non-exclusive, non-transferable trademark licence, ESOP expense, loss on investments treated as stock-in-trade, and foreign exchange hedging loss were each accepted as revenue or business deductions on the facts. Section 14A read with Rule 8D required proper recorded dissatisfaction and was remanded where the factual basis was incomplete. Interest under section 234D and disallowance under section 40(a)(ia) were upheld.</description>
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