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2011 (3) TMI 268 - AT - Income TaxDisallowance - Broken period interest expenditure - As per the decision of the Hon'ble Bombay High Court in the case of American Express International Banking Corporation (2002 -TMI - 12373 - BOMBAY High Court), allowed the assessee's claim, inter alia, observing that since the interest income of the assessee Bank had been taxed by the Department on accrual basis, the interest relatable to the said income is only to be allowed - Decided in favour of assessee. Software expenses - Revenue or Capital expenditure - This issue has been considered threadbare by the Special Bench of the Tribunal in the case of Amway India Enterprises and has laid down various tests for deciding the issue regarding software expenses - This ground is partly allowed. Income on tax free bonds - The matter needs to be restored back to the file of AO in view of the decision of the Hon'ble Bombay High Court in the Godrej and Boyce Mfg. P.Ltd. vs. ACIT (2010 -TMI - 78448 - BOMBAY HIGH COURT) wherein it has been held that Rule 8D is prospective in operation - The assessee, however, submitted that the directions of the ld. CIT(A) do not need any modification as his directions are in conformity with the view taken by the Hon'ble Bombay High Court or making the disallowance on reasonable basis as Rule 8D is not applicable for the present assessment year - Decided in favour of assessee.
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