Inclusion of foreign-branch income upheld, remand of foreign-exchange restatement for fresh AO hearing; education cess disallowed

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....ITAT upheld the AO's inclusion of income of the taxpayer's foreign branches (Singapore and Sri Lanka), dismissing the taxpayer's challenge to exemption/credit treatment. On foreign-currency fluctuation arising from restatement of foreign-branch accounts, ITAT found a breach of natural justice-AO had not given a show-cause notice-and remitted the issue to the AO for de novo adjudication after hearing the taxpayer (allowed for statistical purposes). Regarding deduction of education cess, ITAT reversed the CIT(A)'s allowance, disallowing the cess as an expenditure under the Act and allowing the revenue's appeal.....