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    <title>2026 (6) TMI 1117 - ITAT MUMBAI</title>
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    <description>Banking-company taxation principles under the Income-tax Act were applied to hold that an opening foreign currency translation reserve could not be taxed as income of the year, section 115JB did not apply to a bank governed by banking law, and section 14A read with Rule 8D(2)(ii) could not be invoked for stock-in-trade investments. Reassessment based only on material already on record was treated as a change of opinion and invalid. The note also states that bad debts written off, interest issues on securities and perpetual bonds, NPA interest, HTM premium amortisation, wage revision provision, depreciation on investments and RBI penalty were decided in favour of the assessee, and an assessment in the name of an amalgamated entity was void.</description>
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    <pubDate>Fri, 29 May 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=793736</link>
      <description>Banking-company taxation principles under the Income-tax Act were applied to hold that an opening foreign currency translation reserve could not be taxed as income of the year, section 115JB did not apply to a bank governed by banking law, and section 14A read with Rule 8D(2)(ii) could not be invoked for stock-in-trade investments. Reassessment based only on material already on record was treated as a change of opinion and invalid. The note also states that bad debts written off, interest issues on securities and perpetual bonds, NPA interest, HTM premium amortisation, wage revision provision, depreciation on investments and RBI penalty were decided in favour of the assessee, and an assessment in the name of an amalgamated entity was void.</description>
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