Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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