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    <title>2024 (2) TMI 1591 - ITAT MUMBAI</title>
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    <description>Nostro account charges paid to foreign banks for overseas accounts were held not disallowable for want of tax deduction at source because the debit arose outside India, had no Indian nexus, and was not shown to be managerial, technical, or consultancy service income; the disallowance was deleted. Donation components carved out of CSR spending were held capable of deduction under section 80G if the statutory conditions were otherwise met, since CSR character does not bar a genuine qualifying donation; relief was allowed subject to those conditions. Interest paid by the Indian permanent establishment to its head office was held taxable at the more beneficial treaty rate under Article 11 of the India-UAE DTAA, and the higher domestic rate was not applied.</description>
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      <description>Nostro account charges paid to foreign banks for overseas accounts were held not disallowable for want of tax deduction at source because the debit arose outside India, had no Indian nexus, and was not shown to be managerial, technical, or consultancy service income; the disallowance was deleted. Donation components carved out of CSR spending were held capable of deduction under section 80G if the statutory conditions were otherwise met, since CSR character does not bar a genuine qualifying donation; relief was allowed subject to those conditions. Interest paid by the Indian permanent establishment to its head office was held taxable at the more beneficial treaty rate under Article 11 of the India-UAE DTAA, and the higher domestic rate was not applied.</description>
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