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    <title>2019 (12) TMI 974 - ITAT KOLKATA</title>
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    <description>Corporate guarantee to an overseas associated enterprise was held not to require an arm&#039;s length price adjustment on the facts, and the amendment to section 92B was treated as not changing that position for the controversy. Section 14A read with rule 8D could not be applied where no exempt income had been earned, so the related MAT adjustment under section 115JB also failed. Foreign exchange loss on cancellation and revaluation of forward contracts and foreign currency business loans was treated as revenue in nature because the contracts hedged business risk and the borrowings were for business purposes, making the loss deductible under section 37(1).</description>
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      <description>Corporate guarantee to an overseas associated enterprise was held not to require an arm&#039;s length price adjustment on the facts, and the amendment to section 92B was treated as not changing that position for the controversy. Section 14A read with rule 8D could not be applied where no exempt income had been earned, so the related MAT adjustment under section 115JB also failed. Foreign exchange loss on cancellation and revaluation of forward contracts and foreign currency business loans was treated as revenue in nature because the contracts hedged business risk and the borrowings were for business purposes, making the loss deductible under section 37(1).</description>
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      <pubDate>Wed, 18 Dec 2019 00:00:00 +0530</pubDate>
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