Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Disallowance of provision for foreign exchange fluctuations and loss on forward contracts u/s 43(5) regarding speculative transactions. It clarifies that foreign currency is not a trading commodity, and the provisions of Section 43(5) are not applicable. To qualify as a speculative transaction, there should be a contract for purchase or sale of a commodity settled on a net-net basis without actual delivery. In this case, the contracts were settled by actual delivery, not on a net-to-net basis, and hence do not fall within the meaning of a speculative transaction u/s 43(5). Following the Supreme Court's decision in Woodward Governor India (P.) Ltd, the ITAT upheld the CIT(A)'s order allowing the provision for foreign exchange fluctuations and loss on forward contracts as expenditure for the year.
Disallowance of provision for foreign exchange fluctuations and loss on forward contracts u/s 43(5) regarding speculative transactions. It clarifies that foreign currency is not a trading commodity, and the provisions of Section 43(5) are not applicable. To qualify as a speculative transaction, there should be a contract for purchase or sale of a commodity settled on a net-net basis without actual delivery. In this case, the contracts were settled by actual delivery, not on a net-to-net basis, and hence do not fall within the meaning of a speculative transaction u/s 43(5). Following the Supreme Court's decision in Woodward Governor India (P.) Ltd, the ITAT upheld the CIT(A)'s order allowing the provision for foreign exchange fluctuations and loss on forward contracts as expenditure for the year.
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