s.14A/Rule 8D disallowance deleted for exempt-income securities held as stock-in-trade; s.115JB inapplicable; s.154 rectification quashed
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....ITAT affirmed that disallowance under s.14A read with Rule 8D was not attracted where exempt-income-bearing securities were held as stock-in-trade, and the related Rule 8D(2)(iii) disallowance was deleted in favour of the assessee. The issue of provision for wage revision was remitted to the AO for de novo adjudication after examination of the Memorandum of Settlement. Section 115JB was held inapplicable to the assessee-bank as a corresponding new bank. Shifting loss on transfer from AFS to HTM was held allowable and quantification remitted to the AO. Additions for bad debts and interest accrued but not due were deleted, broken-period interest treated as revenue, penalty u/s 271(1)(c) deleted, and the s.154 rectification quashed.....
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