Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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