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
Tahir Hussain vs Assistant Director Enforcement ... on 24 November, 2022
Author: Anu Malhotra
Bench: Anu
accepted that tested party could be the
local entity or a foreign associate enterprise (AE). Thus, once the foreign AE's
have been rejected ... transactions representing
the import of raw material and components from the associated enterprises. The
assessee accordingly has worked out its PLI at 2.29% after making
CENTRE,
NO.19, RAJAJI SALAI, CHENNAI-600001, REPRESENTED BY IT'S ASSOCIATE
MANAGER-TRADE SERVICES.
4. UNION BANK OF INDIA INDUSTRIAL FINANCE BRANCH, UNION ... BHAVAN MARG, NARIMAN POINT, MUMBAI-400021, REPRESENTED BY
IT'S MANAGER (FOREX).
5. IDBI BANK , IDBI TOWER BRANCH, 3RD FLOOR WTC COMPLEX, CUFFE PARADE
Forex Pvt Ltd (Formerly Known As Nl ... vs The New India Assurance Company on 14 December, 2022
Author: Bharati Dangre
Bench: Bharati Dangre ... ARBITRATION APPLICATION LODGING NO. 35074 OF 2022
Nl Forex Pvt Ltd (formerly Known As Nl Forex....PETITIONER
Ltd)
V/S
The New India Assurance Company
assessee imported certain parts and components from its
Associated enterprises ("AEs") for purpose of manufacturing of
Personal Computers ... risks including market risk, inventory risk,
credit and collection risk, forex risk, warranty and idle capacity
risk. Based on the functions and risks performed
marking up of LIBOR rate by average comparable rate and by Forex risk.
5. The learned CIT(A) has erred both ... facts of the case in holding that
Corporate Guarantee given to associate enterprise is an "international transaction" falling
within the purview of transfer
ground also pleads that only
its corresponding international transaction involving the
corresponding Associated Enterprises "AEs" ought to be considered
and the learned lower ... erred in law and on facts in
rejecting certain items i.e. forex gains/losses as well as provision for
bad and doubtful debts/provisions
under consideration, since, the
assesssee had entered into international transactions with its Associate
Enterprises (AE), a reference was made to the Transfer Pricing Officer ... disallowance under section 14A, writing off of
advances given to BCCI and forex loss. Accordingly, the AO completed the
assessment under section
also entitled for an interest at
CS No. 314/18 Quick Forex Ltd. Vs. Pawan Kumar Gaba & Ors. Page: 4 of 9
-:: 5 ::- Date ... plaintiff that it is submitted that on 21.03.2018,
while the junior Associate Mr. Nagmani Kumar Advocate, C-150 A, C.L.
Joseph Block, Tis Hazari
