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    <title>2025 (2) TMI 1575 - ITAT MUMBAI</title>
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    <description>Banking tax treatment recognises broken-period interest on securities held as stock in trade and premium amortisation on held-to-maturity securities as revenue deductions where RBI, ICDS and accounting requirements are met. Interest on perpetual debt instruments may qualify as business interest where their contractual and accounting character is borrowing. Securities held as stock in trade may not trigger disallowance under section 14A and Rule 8D, and such disallowance is not added to book profit under section 115JB. NPA interest may remain unrecognised under RBI norms. Documented accrual-based wage and expense provisions, including expenses subject to later TDS deduction, and business-purpose corporate club fees require assessment on their supporting facts.</description>
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