Home Highlights February 2015 Year 2015 This

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1. Provision for FCNR fluctuation loss - the losses shown are notional in character and therefore the provision for loss claimed as a deduction is liable to be disallowed. - AT

2. Denial of exchange loss - Unexpalined loss from the income - provisions of section 43A applicability - AS-11 is mandatory and required to be followed in computing the...

3. Penalty proceedings u/s. 270A for underreporting of income - claim of excessive loss - Since, the assessee has neither claimed any benefit of loss against any other...

4. Income tax liability of employees - Remission of income tax liability borne on behalf of the employees - it is also possible that earlier years the assessee has not...

5. TP Adjustment - Reduction of economic adjustment on foreign exchange fluctuation loss - in principle, the foreign exchange fluctuation loss adjustment has to be given...

6. MAT computation - loss arising from foreign exchange fluctuation - Though before us the Revenue contended that the assessee has made only a provision, we find that...

7. Disallowance on provision of loss on derivative contracts - The loss sustained by the assessee due to fluctuation in foreign exchange while implementing export contract...

8. The assessee, a Foreign Portfolio Investor registered in India, entered into Forward Foreign Exchange Contracts (FCC) with HDFC Bank to safeguard against foreign...

9. Nature of loss - Speculative loss or normal business loss - Marked to market loss on hedging of the transaction - The Appellate Tribunal held that speculative...

10. Settlement of case - Set off the unabsorbed business loss - filing of belated return - Indeed, the assessee disclosed the income declared in the settlement commission...

11. Income recognition - No doubt, the Income-tax Act takes into account two points of time at which the liability to tax is attracted, viz., the accrual of the income or...

12. Set off of brought forward business loss against income from other sources - As provision of section 72 are very clear that brought forward business loss can only be set...

13. Disallowance of foreign exchange fluctuation loss - mark to market loss - There is hardly any quarrel on such DRP’s directions are binding on an Assessing Officer u/s...

14. Nature of Liability – Contingent or not – Loss of fluctuation of foreign exchange - the restatement had come at the end of the accounting year and that the present...

15. Block Assessment - Set off or carry forward of loss for p/y years from the undisclosed income determined during Search - It is clear that in computing the total income...