https://www.taxtmi.com/caselaws?id=405854 In a section 260A appeal, questions already covered by binding precedent on section 14A, the related CBDT circular, and licence fee expenditure were not treated as substantial questions of law, so no interference was warranted. The Court also upheld deletion of disallowance of unrealised foreign exchange loss on reinstatement of assets and liabilities, noting that the corresponding currency gain had been taxed earlier and that the revenue could not raise a fresh factual objection for the first time in appeal without having founded it before the lower authorities. The assessee's relief was therefore left undisturbed. en-us Wed, 24 Mar 2021 00:00:00 +0530 Mon, 28 Oct 2024 16:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405854 In a section 260A appeal, questions already covered by binding precedent on section 14A, the related CBDT circular, and licence fee expenditure were not treated as substantial questions of law, so no interference was warranted. The Court also upheld deletion of disallowance of unrealised foreign exchange loss on reinstatement of assets and liabilities, noting that the corresponding currency gain had been taxed earlier and that the revenue could not raise a fresh factual objection for the first time in appeal without having founded it before the lower authorities. The assessee's relief was therefore left undisturbed. Case-Laws Income Tax Wed, 24 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405854