Samsung India Electronics Pvt. Ltd., ... vs Acit, New Delhi on 4 October, 2019
241. This ground pertains to allowability of loss recognized under
accounting standards under marked to market (MTM) guidelines
in respect of forward forex contract which are open and unexpired
on the last date of the balance sheet on account of restatement of
amounts payable and receivable in foreign exchange. This issue
has already been decided by us in ITA No. 5315/Del/2011 for A.Y.
2007-08 under Ground no. 10, ITA No. 52/Del/2013 for A. Yr.
2008-09 under Ground no. 11 and 11.1, ITA No. 1567/DEL/14 for
195
A.Y. 2009-10 under Ground no. 29-31 and ITA No.
6741/DEL/2014 for A.Y. 2010-11 under Ground no. 27 & 28
wherein we have allowed the ground in view of the law being
settled by the Hon'ble Supreme Court in CIT v. Woodward
Governor India Pvt. Ltd. 312 ITR 254 (SC) in this regard. Following
the same, this Ground is allowed.