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    <title>2026 (7) TMI 204 - ITAT MUMBAI</title>
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    <description>Interest received by a foreign bank&#039;s Indian branch from its head office and overseas branches was treated as internal receipt of the same assessee and held not taxable in India; interest from other overseas banks was also excluded because the specific deeming rule was not satisfied, so the addition was deleted. Section 14A was held inapplicable to income taxed at a concessional rate under section 115A, and no disallowance was made for exempt-interest investments where interest-free funds were sufficient. Broken period interest on current securities, employee club membership fees, foreign exchange contract revaluation loss, and RBI levy for CRR/SLR shortfall were treated as deductible. The bad-debt provision write-back issue was remanded for verification of earlier-year treatment.</description>
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      <description>Interest received by a foreign bank&#039;s Indian branch from its head office and overseas branches was treated as internal receipt of the same assessee and held not taxable in India; interest from other overseas banks was also excluded because the specific deeming rule was not satisfied, so the addition was deleted. Section 14A was held inapplicable to income taxed at a concessional rate under section 115A, and no disallowance was made for exempt-interest investments where interest-free funds were sufficient. Broken period interest on current securities, employee club membership fees, foreign exchange contract revaluation loss, and RBI levy for CRR/SLR shortfall were treated as deductible. The bad-debt provision write-back issue was remanded for verification of earlier-year treatment.</description>
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