https://www.taxtmi.com/caselaws?id=313501 ITAT Mumbai allowed the appellant's appeal on multiple grounds. The tribunal held that section 40(a)(i) amendment is retrospective, eliminating TDS disallowance where payee discharged tax liability. Direct expenses incurred outside India were allowed as deductions under section 37(1). Interest paid to head office/overseas branches was permitted following treaty provisions. Refurbishment expenses were fully allowed as revenue expenditure. Expenses attributable to exempt income disallowance was restricted to 1% of exempt income. Securities loss recovery was allowed for statistical purposes pending HC decision. Section 115JB was held inapplicable to banking companies. Head office expenditure was allowed under India-UK DTAA Article 26 without section 44C restrictions. Interest on tax refund was held taxable only upon finality. Salary to expatriate employees was allowed as deduction. en-us Mon, 13 Nov 2023 00:00:00 +0530 Wed, 17 Apr 2024 20:49:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313501 ITAT Mumbai allowed the appellant's appeal on multiple grounds. The tribunal held that section 40(a)(i) amendment is retrospective, eliminating TDS disallowance where payee discharged tax liability. Direct expenses incurred outside India were allowed as deductions under section 37(1). Interest paid to head office/overseas branches was permitted following treaty provisions. Refurbishment expenses were fully allowed as revenue expenditure. Expenses attributable to exempt income disallowance was restricted to 1% of exempt income. Securities loss recovery was allowed for statistical purposes pending HC decision. Section 115JB was held inapplicable to banking companies. Head office expenditure was allowed under India-UK DTAA Article 26 without section 44C restrictions. Interest on tax refund was held taxable only upon finality. Salary to expatriate employees was allowed as deduction. Case-Laws Income Tax Mon, 13 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313501