https://www.taxtmi.com/caselaws?id=465510 The proviso to Section 112(1) of the Income-tax Act remains available even where the assessee has obtained a foreign exchange fluctuation benefit, because that benefit does not by itself defeat concessional taxation under the statutory scheme. The Delhi High Court, following its earlier rulings in Kairn UK Holdings Ltd. and Mitsubhishi Motors Corporation, treated the interaction between Section 48 and Section 112(1) as leaving the concessional rate intact. On that footing, the AAR's view was consistent with precedent, and the challenge to the AAR order failed. en-us Tue, 28 Aug 2018 00:00:00 +0530 Mon, 29 Dec 2025 17:24:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465510 The proviso to Section 112(1) of the Income-tax Act remains available even where the assessee has obtained a foreign exchange fluctuation benefit, because that benefit does not by itself defeat concessional taxation under the statutory scheme. The Delhi High Court, following its earlier rulings in Kairn UK Holdings Ltd. and Mitsubhishi Motors Corporation, treated the interaction between Section 48 and Section 112(1) as leaving the concessional rate intact. On that footing, the AAR's view was consistent with precedent, and the challenge to the AAR order failed. Case-Laws Income Tax Tue, 28 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465510