Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
ITAT upheld the PCIT's revision under s.263, holding the assessment to be erroneous and prejudicial to revenue for permitting a one-time deduction of accumulated foreign exchange loss on ECB repayment. Applying AS-11/ICDS-VI principles, the Tribunal confirmed that exchange differences must be recognized at each balance-sheet date and only the current-year fluctuation (Rs. 2,34,703.29 as found by PCIT) is allowable; the assessee's claimed deduction of Rs. 28,72,92,351/- was disallowed. The matter was set aside to the AO for fresh determination in accordance with PCIT's directions, affording the assessee an opportunity to be heard.
ITAT upheld the PCIT's revision under s.263, holding the assessment to be erroneous and prejudicial to revenue for permitting a one-time deduction of accumulated foreign exchange loss on ECB repayment. Applying AS-11/ICDS-VI principles, the Tribunal confirmed that exchange differences must be recognized at each balance-sheet date and only the current-year fluctuation (Rs. 2,34,703.29 as found by PCIT) is allowable; the assessee's claimed deduction of Rs. 28,72,92,351/- was disallowed. The matter was set aside to the AO for fresh determination in accordance with PCIT's directions, affording the assessee an opportunity to be heard.
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