Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator (PLI). The taxpayers argued that such losses are non-operating, supported by the Safe Harbor Rules and previous judicial decisions. However, the tribunal, aligning with the CIT(A) and TPO, concluded that forex losses related to business activities should be considered operating.
TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator (PLI). The taxpayers argued that such losses are non-operating, supported by the Safe Harbor Rules and previous judicial decisions. However, the tribunal, aligning with the CIT(A) and TPO, concluded that forex losses related to business activities should be considered operating.
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