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    <title>2025 (1) TMI 1604 - ITAT KOLKATA</title>
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    <description>Interest on an income-tax refund arising from erstwhile Indian branches was held not taxable again in the assessee&#039;s hands after amalgamation, because the same receipt had already been assessed in the hands of the former foreign entity and book credit did not change its tax character. The principle applied was that the same income cannot be taxed twice in different hands, and accounting entries are not conclusive of taxability. Long service award and deferred bonus provisions were also allowed under section 43B because the assessee showed that the underlying liabilities had been actually discharged during the year, making the disallowance unsustainable.</description>
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      <description>Interest on an income-tax refund arising from erstwhile Indian branches was held not taxable again in the assessee&#039;s hands after amalgamation, because the same receipt had already been assessed in the hands of the former foreign entity and book credit did not change its tax character. The principle applied was that the same income cannot be taxed twice in different hands, and accounting entries are not conclusive of taxability. Long service award and deferred bonus provisions were also allowed under section 43B because the assessee showed that the underlying liabilities had been actually discharged during the year, making the disallowance unsustainable.</description>
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