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Receipt of interest by foreign banks on foreign currency loans to Indian concerns was taxable on gross basis
Case Law Details
- Case Name
- Bank of Nova Scotia Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 1999- 2000
- Courts
- All ITAT, ITAT Mumbai
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Bank of Nova Scotia Vs ACIT (ITAT Mumbai)
Conclusion: Interest income earned by a foreign bank from foreign currency loans extended to Indian corporates was taxable on a gross basis. Such income could not be reduced by attributing expenditure before the concessional rate of tax was applied.
Held: In the instant case, the dispute arose from assessments of The Bank of Nova Scotia for the assessment years 1999-2000 to 2001-02. For the assessment year 2001-02, AO attributed interest costs of about ₹86 lakh to foreign currency loans advanced to Indian corporates. After attributi...




