counsel that outstanding un-matured foreign
currency forward contracts as at year end which were backed by outstanding
export receivables as at yearend , the learned ... respect to those un-matured outstanding forward foreign
exchange contracts as at yearend which are not backed by outstanding export
receivables as at yearend
said addition include that the assessee being an exporter, made export
of diamonds and outstanding receivable in foreign currency and entered into forward
contracts with ... exchange fluctuations
of export considerations/sale profits. It is the stated reasoning of the assessee, being
an exporter, he has outstanding receivables whose value
revised vide Circular No.40 dated 5-12-2003 by which outstanding
export dues could be written off if the same did not exceed ... export
transactions. As the assessee is doing both import and
export it entered into forward exchange contract in respect
of import and export transaction
notional interest on
outstanding export receivables realized beyond 60 days.
4. The learned Assessing Officer passed a draft assessment order
U/s 144C read with ... addition of Rs.10,62,036/- towards notional
interest on outstanding export receivables realized beyond 60 days
and initiated penalty U/s read with section
erred in law and on facts in holding that outstanding export
receivable amounting to Rs.1,22,05,224/- is to be included in
export ... right in holding that interest allocation
excluded and outstanding export receivable is to be included in export
turnover for the purpose of calculating deduction
said addition include that the assessee being an exporter, made export of
diamonds and outstanding receivable in foreign currency and entered into forward
contracts with ... exchange fluctuations of export considerations/sale profits. It is the
stated reasoning of the assessee, being an exporter, he has outstanding receivables
whose value
towards periodicals and mailings. Assessee publishes a monthly journal, providing information regarding export of electronics and IT industry and receives subscriptions constituting sale consideration from ... conducting award ceremonies i.e. giving awards to deserving companies for outstanding export performances. Assessee incurred expenditure for organizing these ceremonies and received contributions/ sponsorship
Enterprises vs. The ACIT, Jaipur
Particulars Interest on Interest on Total
outstanding export/impo Interest
from/to AEs rt from AEs
as on
31.3.2006
Total ... decision
of the Tribunal in deleting the notional interest on outstanding amount
of export proceeds realised belatedly cannot be faulted
core business of export of diamonds or the
outstanding receivables of export proceeds, in principle, the
impugned FCs constitute ―hedging transaction ... corresponding export
invoice. So long as the total FCs does not exceed the exports of the
year plus outstanding export receivable, the FCs can constitute
core business of export of diamonds or the outstanding
receivables of export proceeds, in principle, the
impugned FCs constitute ―hedging transaction ... corresponding export invoice. So long as the total FCs
does not exceed the exports of the year plus
outstanding export receivable, the FCs can constitute
