https://www.taxtmi.com/caselaws?id=793604 Interest received by an Indian bank branch from its overseas head office and foreign branches on Nostro account was treated as a self-to-self receipt governed by mutuality and therefore not taxable in India. The section 14A disallowance failed because the branch had sufficient interest-free funds and no direct nexus was shown between borrowed funds and exempt investments. Software expenditure for ATM operations was held revenue in nature, and broken period interest on government securities was allowed as deductible. Head office expenditure under section 44C required fresh factual verification because the statutory conditions and nature of the expenses had not been properly examined, and the disallowance linked to income taxable at the special rate under section 115A was directed to be deleted. en-us Wed, 17 Jun 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793604 Interest received by an Indian bank branch from its overseas head office and foreign branches on Nostro account was treated as a self-to-self receipt governed by mutuality and therefore not taxable in India. The section 14A disallowance failed because the branch had sufficient interest-free funds and no direct nexus was shown between borrowed funds and exempt investments. Software expenditure for ATM operations was held revenue in nature, and broken period interest on government securities was allowed as deductible. Head office expenditure under section 44C required fresh factual verification because the statutory conditions and nature of the expenses had not been properly examined, and the disallowance linked to income taxable at the special rate under section 115A was directed to be deleted. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793604