AI Drafter ✕

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required

Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

Try Now →

Call Us / Help / Feedback✕

TMI Blog

Home /

Previous Next

Forex gains on branch merger & excise refunds treated as non-taxable capital receipts.

X X X X Extracts X X X X

Full Text of the Document

X X X X Extracts X X X X

....Assessee offered translation gain from revenue transactions for taxation. CIT(A) deleted disallowance of translation gain from merger of branch balance sheet, holding it non-taxable based on ICAI accounting standards and consistency principle. CBDT circular clarified such translation gains/losses are not real income, upheld by Delhi High Court. Excise duty refunds received by assessee were treated as capital receipts by CIT(A), not taxable revenue receipts, based on Gujarat High Court ruling that refunds aimed to promote industries satisfy 'purpose test' for capital nature. ITAT upheld CIT(A)'s decisions on both issues in favor of assessee.....

Previous Next

Contact Us At :

FAQs :

Most Asked Video Tutorials :

Submit Feedback/Suggestion :

Forex gains on branch merger & excise refunds treated as non-taxable capital receipts.