Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Insurance premium written back under extraordinary items required verification of whether the original disallowance of the larger amount had survived in appeal, and the balance addition was remitted for consequential recomputation after checking that status. Foreign exchange fluctuation loss was treated as a loss that crystallised only in the subsequent year when payment was made at a higher exchange rate, so it was regarded as an unascertained liability on the balance-sheet date and the disallowance, including the book profit add-back, was sustained. Prior period expenditure, including interest to financial institutions, was allowed in the year of payment where the liability had crystallised, and the corresponding disallowance was deleted.
Insurance premium written back under extraordinary items required verification of whether the original disallowance of the larger amount had survived in appeal, and the balance addition was remitted for consequential recomputation after checking that status. Foreign exchange fluctuation loss was treated as a loss that crystallised only in the subsequent year when payment was made at a higher exchange rate, so it was regarded as an unascertained liability on the balance-sheet date and the disallowance, including the book profit add-back, was sustained. Prior period expenditure, including interest to financial institutions, was allowed in the year of payment where the liability had crystallised, and the corresponding disallowance was deleted.
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