https://www.taxtmi.com/caselaws?id=751163 The ITAT Delhi allowed the assessee's appeal on two issues. First, regarding TP adjustment for notional interest on delayed export proceeds from AEs, the tribunal restored the matter to CIT(A) for fresh examination, noting that new contentions can be raised before appellate authorities per SC precedent in Goetze India. Second, concerning depreciation disallowance on exchange fluctuations for assets acquired using FCCB funds, the tribunal directed AO to allow depreciation on capitalized exchange loss, following identical facts from AY 2012-13. The appeal was allowed for statistical purposes on the first issue and substantively on the second. en-us Thu, 04 Apr 2024 00:00:00 +0530 Mon, 08 Apr 2024 09:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751163 The ITAT Delhi allowed the assessee's appeal on two issues. First, regarding TP adjustment for notional interest on delayed export proceeds from AEs, the tribunal restored the matter to CIT(A) for fresh examination, noting that new contentions can be raised before appellate authorities per SC precedent in Goetze India. Second, concerning depreciation disallowance on exchange fluctuations for assets acquired using FCCB funds, the tribunal directed AO to allow depreciation on capitalized exchange loss, following identical facts from AY 2012-13. The appeal was allowed for statistical purposes on the first issue and substantively on the second. Case-Laws Income Tax Thu, 04 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751163