Revenue authority mandates using scheme-specific reversal procedures, not revising original entries, for instrument-based trade/customs benefits effec...
Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
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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