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    <title>2026 (7) TMI 552 - ITAT MUMBAI</title>
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    <description>Branch transactions with a head office or overseas branches were treated as dealings with self, so interest receipts were not taxed in India and the corresponding interest payments were not deductible on the basis of tax neutrality. Expenditure relating to tax-free bond interest under section 14A was not disallowed on the facts, broken period interest on securities held as stock-in-trade was allowed as revenue expenditure, and compensatory interest paid to RBI for SLR shortfall was deductible. By contrast, provision for standard assets was treated as an adjustment for book-profit computation under section 115JA, and interest on foreign currency loans was taxed on a gross basis under section 115A without netting off expenses. Interest on overseas placements with non-resident banks was not deemed to accrue in India under section 9(1)(v), and the additional expatriate salary claim was not entertained.</description>
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