Associated Forex Services Limited,New ... vs Income Tax Officer, Ward 3(3), New ... on 29 August, 2025
ITA No.1699/Del/2025
IN THE INCOME ... 1699/Del/2025
िनधारणवष/Assessment Year:2010-11
ASSOCIATED FOREX SERVICES LIMITED, बनाम Income Tax Officer,
B-214, C.R. Park, New Delhi. Vs. Ward
equity. Since, this is completely a
transaction of capital nature, the associated forex loss cannot be
allowed as a revenue loss to the assessee ... associated concern of
the appellant.
5.3 It would be pertinent to mention here that as the appellant was
engaged in international transactions with its Associated
Enkay Centre
UdyogVihar, Phase C
Gurgaon-122016
Associated Forex Services Ltd.
C-37, Mezzane Floor
Atma Ram House
Connaught Place
New Delhi-110001 ........Opposite Parties ... short the OP-1) is doing the business of selling travellerscheques.Associated Forex Services Ltd. (OP-2) is one of the agents
amounting to Rs. 1,298,559,298 with its associated enterprises.
Assessee considered the FOREX Fluctuation as operating income/expense
the Transactional Net Margin Method ... amounting to Rs. 136,32,59,529 with its associated
enterprises. Assessee treated the FOREX Fluctuation as operating
income/expense and applied the Transactional
exchange purchased for the purpose,
there is also credit risk and forex risk associated. Moreover, in each
such transaction, the arm's length price
Taking into consideration all the kinds of Risk
associated with such transaction like Forex risk, Country risk, Entity
risk, and circumstances further mark
assessee's earning from Associated Enterprises
came to 88% of its total earning and its receivables from Associated
Enterprise had gone up from ... assessee's revenue were from Associated Enterprises and the
debtors were only Associated Enterprises. Thus, according to him,
the directions given
Taking into
consideration all the kinds of Risk associated
with such transaction like Forex risk, Country
risk, Entity risk, and circumstances further mark
fact that the Assessee has fixed price
contract with its associate enterprise and forex fluctuation has no effect on such
fixed price
addition of 100 basis points towards alleged forex risk adjustment
in respect of loans advanced to Associated Enterprises (AEs). The Revenue has
also challenged ... Interest on Advances to
Associated Enterprises
5. The assessee had during the year under consideration advanced loans to
its Associated Enterprises (AEs) in foreign currency
