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    <title>2024 (6) TMI 866 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal deleted additions for notional interest on advances to brokers as these advances did not exist during the assessment year. Disallowance for inflated import purchases was also deleted as high-sea sales transactions resulted in genuine profits, not artificial losses. The tribunal held that export incentives under FPS and VKGUY schemes were capital receipts not liable to tax. ESOP expenses were allowed as deductible under section 37(1). Foreign exchange fluctuation losses were held to be revenue in nature despite capitalization in books. Penalty under section 271(1)(c) was deleted consequent to deletion of primary additions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=754259</link>
      <description>ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal deleted additions for notional interest on advances to brokers as these advances did not exist during the assessment year. Disallowance for inflated import purchases was also deleted as high-sea sales transactions resulted in genuine profits, not artificial losses. The tribunal held that export incentives under FPS and VKGUY schemes were capital receipts not liable to tax. ESOP expenses were allowed as deductible under section 37(1). Foreign exchange fluctuation losses were held to be revenue in nature despite capitalization in books. Penalty under section 271(1)(c) was deleted consequent to deletion of primary additions.</description>
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