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The ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A) in favour of the assessee. It was held that the foreign exchange fluctuation loss was not a mere notional or speculative loss but a deductible business expenditure, the factual matrix being distinct from precedents relied on by the Revenue. The ITAT accepted that the CIT(A) correctly applied the governing principles on recognition of foreign exchange losses. On the issue of carry forward of losses under s.79, the ITAT affirmed that there was no change in shareholding between the year of loss and the relevant assessment year, post-amalgamation, and statutory conditions were satisfied. Finding no perversity or legal infirmity, the ITAT sustained the relief granted and rejected all grounds raised by the Revenue.
The ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A) in favour of the assessee. It was held that the foreign exchange fluctuation loss was not a mere notional or speculative loss but a deductible business expenditure, the factual matrix being distinct from precedents relied on by the Revenue. The ITAT accepted that the CIT(A) correctly applied the governing principles on recognition of foreign exchange losses. On the issue of carry forward of losses under s.79, the ITAT affirmed that there was no change in shareholding between the year of loss and the relevant assessment year, post-amalgamation, and statutory conditions were satisfied. Finding no perversity or legal infirmity, the ITAT sustained the relief granted and rejected all grounds raised by the Revenue.
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