Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Gains from cancellation or early settlement of forward foreign exchange contracts entered solely to hedge debt investments retain the capital character of the underlying capital assets. The contracts were restricted by the underlying foreign-exchange exposure, could not subsist independently after disposal of the securities, and their settlement extinguished contractual rights and obligations, constituting a transfer. Accordingly, the gain was treated under Capital Gains rather than Income from Other Sources. Consistent coordinate Bench decisions in the same taxpayer's case remained binding despite pending High Court appeals, absent any stay or reversal, and were followed. Penalty-initiation objections were described as premature.
Gains from cancellation or early settlement of forward foreign exchange contracts entered solely to hedge debt investments retain the capital character of the underlying capital assets. The contracts were restricted by the underlying foreign-exchange exposure, could not subsist independently after disposal of the securities, and their settlement extinguished contractual rights and obligations, constituting a transfer. Accordingly, the gain was treated under Capital Gains rather than Income from Other Sources. Consistent coordinate Bench decisions in the same taxpayer's case remained binding despite pending High Court appeals, absent any stay or reversal, and were followed. Penalty-initiation objections were described as premature.
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