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    <title>2026 (2) TMI 159 - ITAT MUMBAI</title>
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    <description>Disallowance of expenditure attributable to tax-exempt income was found unsustainable where shares are stockintrade, and the disallowance under the provision for exempt income is deleted. Amortisation of lease premium is capital in nature; depreciation under the depreciation provision is to be allowed, reducing income. Profits of foreign branches are taxable in India and must be included in return income; credit for taxes paid abroad is permissible under applicable double taxation mechanisms and is to be adjudicated de novo by the assessing officer. Provision for country risk and foreign tax credit issues are restored for fresh adjudication. Bad debts written off under irrecoverable debt are allowed; several bankingspecific deductions and MAT applicability rulings favour the assessee, while a penalty for AML/CFT violation is disallowed as a business deduction.</description>
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      <description>Disallowance of expenditure attributable to tax-exempt income was found unsustainable where shares are stockintrade, and the disallowance under the provision for exempt income is deleted. Amortisation of lease premium is capital in nature; depreciation under the depreciation provision is to be allowed, reducing income. Profits of foreign branches are taxable in India and must be included in return income; credit for taxes paid abroad is permissible under applicable double taxation mechanisms and is to be adjudicated de novo by the assessing officer. Provision for country risk and foreign tax credit issues are restored for fresh adjudication. Bad debts written off under irrecoverable debt are allowed; several bankingspecific deductions and MAT applicability rulings favour the assessee, while a penalty for AML/CFT violation is disallowed as a business deduction.</description>
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