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
Wns Global Services P. Ltd, Mumbai vs Dcit Cir 14(3)(1), Mumbai on 19
This loss is solely an accounting loss, worked out on
restatement of forex liabilities as per AS-11 which was infact
accounted in the books ... forex loss
in the relevant financial year. The appellant was very much aware of
its transactions in foreign exchange with its associated concerns and
liabilities
follow:
The assessee is a wholly owned subsidiary of JDA
Software Inc. [Associated Enterprises (AE)]. The assessee is
primarily engaged in the business of development ... follow:-
Operating Income Rs.1,10,75,19,991
Operating Cost (Less forex loss) Rs.96,41,66,619
Operating Profit (Op. income
11317 OF 2019(L)
4
JUDGMENT
The petitioners are working as Associate (clerical cadre) in the State
Bank of India. The Writ Petition is filed ... that all the employees
except those who are having transaction rights in Forex Software (Mercury
FX) have been exempted from vacation policy. Therefore, petitioners
Serve Ltd.
15. The DRP also directed the AO to consider Forex income, bank charges and
provision for doubtful debts as operating in nature ... International transactions
undertaken the assessee company with its associates/parent enterprise.
2. "On the facts and in the circumstances of the case
Technology Enabled Services (ITES) in the field of data processing to its
associated enterprises under agreement dated 20.02.2010.
5. The international transactions entered into ... operating margin of the appellant company,
the TPO excluded the following:
i. FOREX Fluctuation
ii. Domestic Revenue
iii. Prior period expenses
8. The first grievance
parent company;
b) Addition of Rs. 2,98,46,447/- by treating forex loss as speculative
loss;
c) Addition ... above, the assessee is also aggrieved by the
treatment of forex exchange gain as non-operating income.
4. Representatives of both the sides were heard
M/S Wipro Limited , Bnagalore vs Joint Commissioner Of Income Tax ... on 5 October, 2020
Government Of India vs Vedanta Limited (Formerly Cairn India ... on 16 September, 2020
Equivalent citations
