https://www.taxtmi.com/caselaws?id=311697 Interest disallowance under section 14A was not warranted where the bank had sufficient interest-free funds to cover tax-free bond investments. Interest paid by an Indian branch to its head office and overseas branches was treated as a payment to self, so it was not taxable in India and withholding-based disallowance under section 40(a)(ia) failed. Broken period interest on securities held as stock-in-trade remained an allowable business deduction. Bad debt deduction under section 36(1)(vii) was not to be restricted in the manner suggested by the Assessing Officer, and salary paid to expatriate employees for services rendered wholly in India was not hit by section 44C. The transfer pricing adjustment for correspondent banking services was deleted because the selected comparables were functionally dissimilar. en-us Fri, 21 Apr 2023 00:00:00 +0530 Tue, 09 Jan 2024 11:51:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311697 Interest disallowance under section 14A was not warranted where the bank had sufficient interest-free funds to cover tax-free bond investments. Interest paid by an Indian branch to its head office and overseas branches was treated as a payment to self, so it was not taxable in India and withholding-based disallowance under section 40(a)(ia) failed. Broken period interest on securities held as stock-in-trade remained an allowable business deduction. Bad debt deduction under section 36(1)(vii) was not to be restricted in the manner suggested by the Assessing Officer, and salary paid to expatriate employees for services rendered wholly in India was not hit by section 44C. The transfer pricing adjustment for correspondent banking services was deleted because the selected comparables were functionally dissimilar. Case-Laws Income Tax Fri, 21 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311697