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    <title>2025 (3) TMI 1781 - ITAT PUNE</title>
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    <description>A further addition for notional foreign exchange gain or loss on external commercial borrowings was impermissible because the assessee consistently restated the foreign currency borrowing year by year under the applicable accounting framework, and the same exchange fluctuation effect had already been reflected in tax computations, so sustaining the addition would have caused double taxation. The addition for reversal of provision for slow moving inventory was also unsustainable because the provision had been taxed in the earlier year and the reversal merely neutralised that earlier charge without creating a fresh deductible expense. Revenue&#039;s appeals failed; the cross objections were not pressed and did not survive.</description>
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      <title>2025 (3) TMI 1781 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=469415</link>
      <description>A further addition for notional foreign exchange gain or loss on external commercial borrowings was impermissible because the assessee consistently restated the foreign currency borrowing year by year under the applicable accounting framework, and the same exchange fluctuation effect had already been reflected in tax computations, so sustaining the addition would have caused double taxation. The addition for reversal of provision for slow moving inventory was also unsustainable because the provision had been taxed in the earlier year and the reversal merely neutralised that earlier charge without creating a fresh deductible expense. Revenue&#039;s appeals failed; the cross objections were not pressed and did not survive.</description>
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