2018 (2) TMI 306

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....ear 200910. 2. Mr. Pinto, learned Counsel for the Revenue, urges the following reframed question of law for our consideration: 1. Whether on the facts and in the circumstance of the case and in law, the Tribunal is in error in treating foreign exchange losses as operating expenditure when these transactions did not have a significant impact on the operation of the company? 2. Whether on the facts and circumstances of the case and in law, the Tribunal was right in holding that the loss of eligible units are not to be deducted from the profits of the eligible units for the purpose of Section 10A deduction? 3. Whether on the facts and circumstances of the case and in law, the Tribunal was right in relying on the d....

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....of allotment of land from the State Government. During the assessment proceedings, the Respondent claimed that the purpose/object of the subsidy received in the form of land was capital in nature as purpose/object of giving subsidy was to generate employment to over 3000 people in Hyderabad. This was not accepted by a draft assessment order dated 15 February 2013. The Assessing Officer held that an amount of Rs. 1.20 Crores is to be brought to tax as income as he considered it to be revenue in nature. (b) Being aggrieved with the draft assessment order, the Respondent filed an application to the Dispute Resolution Panel ("DRP" for short) under Section 144C(I) of the Act. By an order dated 31 October 2013, the DRP upheld the view of Asses....