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    <title>2024 (6) TMI 987 - CALCUTTA HIGH COURT</title>
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    <description>HC dismissed revenue&#039;s appeals. It upheld the Tribunal/CIT(A) finding that foreign exchange loss on assignment of a loan by a foreign parent to the assessee (an NBFC) was not taxable as revenue expenditure and the Tribunal&#039;s reliance on earlier precedents was proper, so the issue failed against revenue. Allowance of insurance and audit fees was sustained as factually supported. The Tribunal correctly declined to apply the Finance Act, 2022 amendment to section 14A retrospectively. Claims for upward adjustment under section 115JB were treated as factual; revenue&#039;s challenge did not succeed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=754380</link>
      <description>HC dismissed revenue&#039;s appeals. It upheld the Tribunal/CIT(A) finding that foreign exchange loss on assignment of a loan by a foreign parent to the assessee (an NBFC) was not taxable as revenue expenditure and the Tribunal&#039;s reliance on earlier precedents was proper, so the issue failed against revenue. Allowance of insurance and audit fees was sustained as factually supported. The Tribunal correctly declined to apply the Finance Act, 2022 amendment to section 14A retrospectively. Claims for upward adjustment under section 115JB were treated as factual; revenue&#039;s challenge did not succeed.</description>
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