Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
