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    <title>2024 (11) TMI 1188 - ITAT MUMBAI</title>
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    <description>Section 14A disallowance was held inapplicable where exempt income arose from shares and securities held as stock-in-trade. Interest on perpetual debt instruments was treated as deductible business expenditure, and recovery of bad debts from rural branches was held outside section 41(4) where no deduction had been claimed under the relevant second stream of section 36(1)(vii). The Tribunal also followed precedent that section 115JB does not apply to a corresponding new bank not registered under the Companies Act, making MAT adjustments academic. Broken period interest, amortisation of premium on held-to-maturity securities, unrealised NPA interest, recomputed deduction under section 36(1)(viii), loss on sale of NPAs to an ARC, and payments to RBI for regulatory non-compliance were all treated as allowable or outside the bar on deduction.</description>
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    <pubDate>Fri, 27 Sep 2024 00:00:00 +0530</pubDate>
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      <description>Section 14A disallowance was held inapplicable where exempt income arose from shares and securities held as stock-in-trade. Interest on perpetual debt instruments was treated as deductible business expenditure, and recovery of bad debts from rural branches was held outside section 41(4) where no deduction had been claimed under the relevant second stream of section 36(1)(vii). The Tribunal also followed precedent that section 115JB does not apply to a corresponding new bank not registered under the Companies Act, making MAT adjustments academic. Broken period interest, amortisation of premium on held-to-maturity securities, unrealised NPA interest, recomputed deduction under section 36(1)(viii), loss on sale of NPAs to an ARC, and payments to RBI for regulatory non-compliance were all treated as allowable or outside the bar on deduction.</description>
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