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    <title>2019 (1) TMI 1346 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC confined admission of the appeal to the issue of section 44C and head office expenses. The proposed question on disallowance relating to unmatured forward foreign exchange transactions was treated as already concluded against the Revenue and therefore did not raise a substantial question of law. The suggested issue on a non-resident assessee&#039;s alleged option between assessment under the Income-tax Act and the applicable DTAA was not entertained because it did not arise from the Tribunal&#039;s order and had not been urged before the Tribunal. Questions 2 and 3 were rejected from consideration.</description>
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    <pubDate>Mon, 21 Jan 2019 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=374181</link>
      <description>The Bombay HC confined admission of the appeal to the issue of section 44C and head office expenses. The proposed question on disallowance relating to unmatured forward foreign exchange transactions was treated as already concluded against the Revenue and therefore did not raise a substantial question of law. The suggested issue on a non-resident assessee&#039;s alleged option between assessment under the Income-tax Act and the applicable DTAA was not entertained because it did not arise from the Tribunal&#039;s order and had not been urged before the Tribunal. Questions 2 and 3 were rejected from consideration.</description>
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      <pubDate>Mon, 21 Jan 2019 00:00:00 +0530</pubDate>
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