2019 (3) TMI 2113

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....CA For the Revenue : Smt. Neera Malhothra, JCIT ORDER PER LALIET KUMAR, JUDICIAL MEMBER : This is an appeal filed by the Revenue against the order of the DCIT, Circle -6(1)(1), Bengaluru, dt.07.01.2015, passed u/s. 143(3) r.w.s.144C of the Act, in pursuance to the directions of the DRP, for the assessment year 2010-11. 02. The Revenue has raised the following effective ground : ....

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....onsideration on account of international transactions for the same assessment year, then the assessee is entitled to treat it as operating in nature. 05. We have heard the rival contentions and perused the record. For ready reference, we are reproducing herein below para 6.1 and 6.2.1 of the decision of the Tribunal in Mercedez Benz (supra) : 6.1 In these grounds, the Revenue contends ....

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....of another co ordinate bench of this Tribunal in the assessee's own case for Assessment Year 2007-08. We find that another co-ordinate bench of this Tribunal in the assessee's own case for Assessment Year 2010-11 in its order in IT(TP)A Nos.291 & 427/Bang/2015 dt.24.6.2016 has held that if foreign exchange gain / loss is operational in nature if it is linked to the exports / imports relate....