2020 (2) TMI 1649

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....e Respondent : Mrs. Vijayaprabha, JCIT ORDER PER M. BALAGANESH, ACCOUNTANT MEMBER: This appeal of the assessee arise out of the order of the Ld. Commissioner of Income Tax (Appeals)-8, Chennai vide proceedings in ITA No.70/17-18, dated 28.06.2018 against the order passed by the DCIT, Corporate Circle-4(2), Chennai (AO) u/s. 143(3) of the Income Tax Act, 1961 (hereafter 'the Act') dated 27.12.20....

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.... to tax. The Ld. A.O in the scrutiny assessment proceedings completed u/s. 143(3) dated 29.12.2016 had also assessed the said exchange gain as a taxable receipt. During the year under consideration on receipt of the loan from the foreign subsidiary, pursuant to the conversion of the amounts received in foreign currency into Indian currency, the assessee incurred exchange fluctuation loss and claim....

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....by the assessee to its foreign subsidiary in the earlier years and at the time of re-statement of the said loans in earlier years at the exchange rate prevailing at the end of the year, it had resulted in exchange gain which has been duly offered to tax by the assessee voluntarily and assessed as such by the Revenue in the scrutiny assessment proceedings completed u/s. 143(3) of the Act. During th....