Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
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