https://www.taxtmi.com/caselaws?id=777490 ITAT DELHI - AT held that forex derivative losses were genuine hedging losses, not speculative, and allowed their deduction; the 1% ad-hoc closing-stock addition was deleted. The DRP acted beyond jurisdiction in introducing a new disallowance (payments to a marketing committee) not raised by the AO. Transfer-pricing adjustments on inter-company loans are to be limited to LIBOR; notional interest on delayed receivables under section 92B was disallowed as the amendment is prospective and the transactions were not international transactions for the years in issue. AO directed to compute notional commission on corporate guarantees at 1%. en-us Fri, 22 Aug 2025 00:00:00 +0530 Sat, 30 Aug 2025 08:31:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777490 ITAT DELHI - AT held that forex derivative losses were genuine hedging losses, not speculative, and allowed their deduction; the 1% ad-hoc closing-stock addition was deleted. The DRP acted beyond jurisdiction in introducing a new disallowance (payments to a marketing committee) not raised by the AO. Transfer-pricing adjustments on inter-company loans are to be limited to LIBOR; notional interest on delayed receivables under section 92B was disallowed as the amendment is prospective and the transactions were not international transactions for the years in issue. AO directed to compute notional commission on corporate guarantees at 1%. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777490