Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The ITAT allowed the appellant's appeal, setting aside the revision order of the revenue which had disallowed claimed foreign exchange loss. The Tribunal found the appellant consistently follows the mercantile system and recognizes exchange differences on year-end valuation of outstanding foreign currency liabilities; therefore exchange loss recorded in the profit and loss account is genuine under the accounting method adopted. The ITAT concluded that, notwithstanding lack of current operations or actual settlement, year-end revaluation of a USD liability legitimately produces taxable accounting loss and is allowable, and directed restoration of the claim.
The ITAT allowed the appellant's appeal, setting aside the revision order of the revenue which had disallowed claimed foreign exchange loss. The Tribunal found the appellant consistently follows the mercantile system and recognizes exchange differences on year-end valuation of outstanding foreign currency liabilities; therefore exchange loss recorded in the profit and loss account is genuine under the accounting method adopted. The ITAT concluded that, notwithstanding lack of current operations or actual settlement, year-end revaluation of a USD liability legitimately produces taxable accounting loss and is allowable, and directed restoration of the claim.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
