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2014 (2) TMI 743 - AT - Income TaxInterest paid to Head Office allowed Held that:- As decided in assessees own case, The interest income received from Head Office is not chargeable to tax being it is an income to self - the interest paid by the Assessee Branch PE in India to Head Office is also not to be allowed as deduction Decided in favour of Revenue. Disallowance of Deduction u/s 37 of the Act Disallowance made u/s 40(a)(i) of the Act Payment made to NOSTRO Held that:- The travelling expenses incurred by the Head Office on travelling of its own staff and directly in connection with India branches is allowable u/s. 37(1) of the Act and section 44C is not applicable to it Relying upon CIT vs. Emirates Commercial Bank Ltd. [2003 (4) TMI 2 - BOMBAY HIGH COURT] - Revenue could not controvert the fact Decided against Revenue. Claim of bad debt of the amount Held that:- The claim of bad debts has been allowed in earlier assessment year 1995-96 and consequently the order of the ld. CIT(A) is to be reversed and confirm the action of Assessing Officer Decided in favour of Revenue. Applicability of Section 14A of the Act Interest received from the head office Held that:- The interest income received from head Office does not give rise to income - the expenditure incurred by the Assessee in relation to such income cannot be allowed the additional groud taken by the department is to be allowed in favour of the department and against the Assessee and that the provisions of section 14A are applicable on the exempt interest income earned from Head Office/overseas branches Decided in favour of Revenue.
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