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    <title>2023 (9) TMI 1763 - ITAT MUMBAI</title>
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    <description>Recurring tax issues in the assessee bank&#039;s case were addressed by following prior-year rulings: interest and bank charges paid to the head office and overseas branches were treated as allowable, and related interest was held not taxable in India. Direct head-office expenses were allowed as business deduction, while the tax-credit claim was sent back for verification. The section 14A disallowance was restricted to 2% of exempt income, and interest under section 234D was permitted to be netted against interest under section 244A. Higher depreciation on motor cars was allowed, ECB-related additions were deleted, the transfer pricing adjustment on derivative marketing commission was rejected, and section 115JB was held inapplicable to a banking company for the relevant pre-amendment period.</description>
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      <description>Recurring tax issues in the assessee bank&#039;s case were addressed by following prior-year rulings: interest and bank charges paid to the head office and overseas branches were treated as allowable, and related interest was held not taxable in India. Direct head-office expenses were allowed as business deduction, while the tax-credit claim was sent back for verification. The section 14A disallowance was restricted to 2% of exempt income, and interest under section 234D was permitted to be netted against interest under section 244A. Higher depreciation on motor cars was allowed, ECB-related additions were deleted, the transfer pricing adjustment on derivative marketing commission was rejected, and section 115JB was held inapplicable to a banking company for the relevant pre-amendment period.</description>
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