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    <title>Interest taxability on internal bank placements: payment-to-self receipts escaped tax, while bad-debt write-off and refund interest were addressed.</title>
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    <description>Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty&#039;s separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer&#039;s borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors&#039; accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.</description>
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    <pubDate>Fri, 26 Jun 2026 07:07:29 +0530</pubDate>
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      <title>Interest taxability on internal bank placements: payment-to-self receipts escaped tax, while bad-debt write-off and refund interest were addressed.</title>
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      <description>Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty&#039;s separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer&#039;s borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors&#039; accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.</description>
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      <pubDate>Fri, 26 Jun 2026 07:07:29 +0530</pubDate>
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