ESOP expenditure allowed as FMV difference; long-term capital gain issue sent back for collector rate determination; deferred income additions disallo...
Appeal allowed; impugned order quashed as regulator failed to prove nexus or manipulative scheme; sale genuine - s.12A(a)-(c), Regs 3(a)-(d),4(1),4(2)...
Appellant's ring-back tone service held OIDAR, taxable domestically for 01.07.2012-31.07.2016; liability confirmed, penalties vacated, remanded for re...
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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