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    <title>2025 (2) TMI 1861 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that section 14A disallowance could not be sustained on securities held by a bank as stock in trade, so the addition was deleted. It further held that interest on NPAs is taxable only in line with RBI recognition norms under section 43D, and that broken period interest on purchase of securities is allowable as revenue expenditure. The Tribunal also held that section 115JB does not apply to a corresponding new bank, and that interest on perpetual bonds remains deductible because the instruments are borrowings, not equity. Foreign branch income in treaty countries was, however, held taxable in India, with treaty credit available.</description>
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      <title>2025 (2) TMI 1861 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=468685</link>
      <description>ITAT Mumbai held that section 14A disallowance could not be sustained on securities held by a bank as stock in trade, so the addition was deleted. It further held that interest on NPAs is taxable only in line with RBI recognition norms under section 43D, and that broken period interest on purchase of securities is allowable as revenue expenditure. The Tribunal also held that section 115JB does not apply to a corresponding new bank, and that interest on perpetual bonds remains deductible because the instruments are borrowings, not equity. Foreign branch income in treaty countries was, however, held taxable in India, with treaty credit available.</description>
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