https://www.taxtmi.com/caselaws?id=778076 ITAT MUMBAI (AT) dismissed the DTAA beneficial-rate challenge following Special Bench precedent. Rural advances of an amalgamated NBFC are includible for deduction under s.36(1)(viia) with an 8.5% benchmark; quantum remitted to AO for verification. Loss/gain on sale of property acquired in satisfaction of debt is business loss/gain; factual inquiry remitted. Deduction under s.36(1)(viia) for provisions on standard assets, additional ESOP cost, and amortization of HTM premium are to be examined/allowed as indicated and remitted where factual verification needed. s.14A disallowance under Rule 8D deleted. QIP issue expenses qualify under s.35D. Credit-card bad debts allowed under s.36(1)(vii). Interest on perpetual bonds allowed as deductible borrowing cost. Broken-period interest allowed per HC position. en-us Thu, 17 Jul 2025 00:00:00 +0530 Wed, 10 Sep 2025 08:39:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778076 ITAT MUMBAI (AT) dismissed the DTAA beneficial-rate challenge following Special Bench precedent. Rural advances of an amalgamated NBFC are includible for deduction under s.36(1)(viia) with an 8.5% benchmark; quantum remitted to AO for verification. Loss/gain on sale of property acquired in satisfaction of debt is business loss/gain; factual inquiry remitted. Deduction under s.36(1)(viia) for provisions on standard assets, additional ESOP cost, and amortization of HTM premium are to be examined/allowed as indicated and remitted where factual verification needed. s.14A disallowance under Rule 8D deleted. QIP issue expenses qualify under s.35D. Credit-card bad debts allowed under s.36(1)(vii). Interest on perpetual bonds allowed as deductible borrowing cost. Broken-period interest allowed per HC position. Case-Laws Income Tax Thu, 17 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778076