2023 (6) TMI 1168

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.... fixed for hearing on 26.11.2021, 24.03.2022, 23.06.2022, 26.08.2022, 16.12.2022, 27.04.2023 and 20.06.2023, i.e., today. On none of these occasions, the assessee was present either in person or through his Authorized Representative. 3. The only issue to be decided in this appeal is as to whether learned PCIT was justified in invoking revisional jurisdiction under section 263 of the Act by cancelling assessment order framed by the learned Assessing Officer and directing him to deny the claim of deduction under section 80IC of the Act in respect of exchange rate fluctuation income, interest income and insurance claim in the facts and circumstances of the instant case. 4. We have heard learned DR and perused the materials available on recor....

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....ported from Japan & Korea. The purchases of raw materials at the time of receipt of the materials at factory have been booked by applying the rate of dollar on the date of purchases whereas payment is made after credit period is over by applying the rate of dollar at the time of payment. Therefore, difference in rates of dollar on the date of purchase and on the date of payment arises. The difference so arises has been shown separately as per requirement of Accounting Standard. Therefore, the exchange rate fluctuation difference is part and parcel of cost of purchases which is part of manufacturing activities and is eligible for deduction u/s 80IC. ii) Interest income:- Regarding interest income he stated that to avail Letter of Credit fr....