Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
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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