2013 (9) TMI 1112

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..... OF INCOME TAX [2010 (3) TMI 81 - SUPREME COURT]
SRI H.L. KARWA, PRESIDENT, AND SHRI N.K.BILLAIYA, AM For the Appellant : Shri Aarsi Prasad For the Respondent : Shri K.A. Vaidyalingan O R D E R PER N.K. BILLAIYA, AM: This appeal by the Revenue is preferred against the order of the CIT(A)-27, Mumbai, dated 25/08/2011, pertaining to A.Y.2008-09. 2. The revenue has raised two substantive .....

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..... e not disallowed being a notional loss. 4. Assessee filed a detailed reply dated 29.11.2010 and explained that it is engaged in the business of export of diamonds goods are sold on credit and therefore, it is always exposed to foreign currency fluctuation risk. In order to hedge the risk of fluctuation of currency rate, it has entered into forward exchange contracts. It was further explained that .....

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..... a). The CIT(A) has also considered the decision of the Hon'ble Supreme Court in the case of CIT v/s Woodward Governor India Pvt. Ltd. 312 ITR 254, ONGC v/s CIT, 322 ITR 180, following these decisions, the CIT(A) deleted the additions. 6. Aggrieved by this revenue is before us. 6. The DR strongly relied upon the findings of the AO. Per contra the counsel for the assessee in addition to the decisio .....

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