Foreign exchange fluctuation liability disallowance not disturbed after binding Supreme Court precedent settled the issue.

The Tribunal deleted the disallowance for foreign exchange fluctuation liability by applying Woodward Governor India, a view already affirmed by the Supreme Court. With the legal position settled, the Delhi HC held that the issue was no longer open for reconsideration in an appeal under Section 260A. The addition was therefore left undisturbed and the appeal was dismissed.

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Issues: Whether the deletion of the disallowance made on account of foreign exchange fluctuation liability called for interference in an appeal under Section 260A of the Income-tax Act, 1961.

Analysis: The Tribunal had deleted the addition by following the binding decision in Woodward Governor India, which had also been affirmed by the Supreme Court. In view of that settled position, the issue ceased to be open for reconsideration.

Conclusion: The addition on account of foreign exchange fluctuation liability was not interfered with and the appeal was dismissed.

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