Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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