https://www.taxtmi.com/caselaws?id=784542 Disallowance under s.14A r/w Rule 8D was held unsustainable where the exempt-income-yielding shares were held as stock-in-trade, consistent with post-Maxopp jurisprudence; the disallowance was deleted. Profits of foreign branches were not excludible from Indian taxation under the Act/DTAA framework; the exclusion claim was rejected and the related ground was dismissed, but the matter was restored to the AO to grant FTC under applicable DTAAs upon verification of taxes paid abroad and non-claim of earlier credit. FTC carried forward for prior-year foreign taxes was held allowable in the year the corresponding foreign income became taxable in India; the issue was remitted for quantification/verification. s.115JB (MAT) was held inapplicable to the assessee bank; MAT was deleted. Deduction u/s 36(1)(viia) was to be computed before set-off of brought-forward losses; relief was allowed. The AO was directed to compute refund interest u/s 244A as per precedent; revenue objection failed. en-us Tue, 23 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 18:10:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784542 Disallowance under s.14A r/w Rule 8D was held unsustainable where the exempt-income-yielding shares were held as stock-in-trade, consistent with post-Maxopp jurisprudence; the disallowance was deleted. Profits of foreign branches were not excludible from Indian taxation under the Act/DTAA framework; the exclusion claim was rejected and the related ground was dismissed, but the matter was restored to the AO to grant FTC under applicable DTAAs upon verification of taxes paid abroad and non-claim of earlier credit. FTC carried forward for prior-year foreign taxes was held allowable in the year the corresponding foreign income became taxable in India; the issue was remitted for quantification/verification. s.115JB (MAT) was held inapplicable to the assessee bank; MAT was deleted. Deduction u/s 36(1)(viia) was to be computed before set-off of brought-forward losses; relief was allowed. The AO was directed to compute refund interest u/s 244A as per precedent; revenue objection failed. Case-Laws Income Tax Tue, 23 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784542