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    <title>2026 (2) TMI 159 - ITAT MUMBAI</title>
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    <description>For a banking assessee, section 14A disallowance on dividend from shares held as stock-in-trade was deleted because the income was incidental to business and the nexus-based disallowance did not survive. Bad-debt write-offs were allowed under sections 36(1)(vii), 36(1)(viia) and 36(2) because the provisions and anti-double-deduction principle did not justify reducing the claim on the facts. Section 115JB was held inapplicable to the bank. Broken period interest, interest on perpetual bonds, premium on HTM securities, and deferred guarantee commission were largely treated in the assessee&#039;s favour, while lease-premium amortisation was disallowed. Regulatory penalties were deductible only where compensatory, not where imposed for prohibited-law offences.</description>
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    <pubDate>Fri, 30 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (2) TMI 159 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=785964</link>
      <description>For a banking assessee, section 14A disallowance on dividend from shares held as stock-in-trade was deleted because the income was incidental to business and the nexus-based disallowance did not survive. Bad-debt write-offs were allowed under sections 36(1)(vii), 36(1)(viia) and 36(2) because the provisions and anti-double-deduction principle did not justify reducing the claim on the facts. Section 115JB was held inapplicable to the bank. Broken period interest, interest on perpetual bonds, premium on HTM securities, and deferred guarantee commission were largely treated in the assessee&#039;s favour, while lease-premium amortisation was disallowed. Regulatory penalties were deductible only where compensatory, not where imposed for prohibited-law offences.</description>
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      <pubDate>Fri, 30 Jan 2026 00:00:00 +0530</pubDate>
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