regards to the
order of CIT(A) confirming the disallowance of forward premium
treating the same as capital expenditure by applying the provisions
of section ... Commissioner of Income tax (Appeals) erred in confirming the
disallowance of forward premium by wrongly treating the same as capital
expenditure by applying the provisions
assessee submitted that the claim of the forward premium as revenue in
nature was in accordance with prescribed norms ... allow the
deduction for the amortized sum of forward premium claimed by way of
hedging cost.
8.7 The next component of the impugned disallowance
forward agreement executed for
purchase of US $ in future at a fixed rate, ignoring the fact that the liability in
respect of forward cover premium ... confirming the disallowance in respect of Amortization of loss
on forward cover premium of Rs.1,13,35,384/- being a part of the forward
confirming the action of AO in making addition of
forex forward premium charges of Rs.10,56,75,723/-. For this,
assessee has raised ... Commissioner of Income tax (Appeals) ought to have appreciated
that the forward premium of Rs.10,56,75,723/- has been incurred in relation
inception of a forward exchange contract is accounted for separately from the
exchange differences on the forward exchange contract. The premium or discount
that arises ... inception of the forward exchange contract and
the forward rate specified in the contract. Exchange difference on a forward
exchange contract is the difference between
Chny/2018.
Issue No. 2 - Disallowance of forward contract premium
incurred by the Appellant amounting to Rs.8,85,53,023
6. The learned ... erred in disallowing forward
contract premium incurred by the Appellant during the subject year
on account of its import and export transactions
Chny/2018.
Issue No. 2 - Disallowance of forward contract premium
incurred by the Appellant amounting to Rs.8,85,53,023
6. The learned ... erred in disallowing forward
contract premium incurred by the Appellant during the subject year
on account of its import and export transactions
Chny/2018.
Issue No. 2 - Disallowance of forward contract premium
incurred by the Appellant amounting to Rs.8,85,53,023
6. The learned ... erred in disallowing forward
contract premium incurred by the Appellant during the subject year
on account of its import and export transactions
charges on
forward contract on import of raw materials
7.1 The facts as noted are that, the assessee had incurred forward
contract premium charges, which ... delete the impugned addition and allow
the deduction for forward premium charges paid by the assessee. These
grounds are therefore allowed.
8. Ground
discounting / payment.
Whatever be the nomenclature given to the term, whether forward
premium / discount on the foreign exchange loan or any other, the fact
remains ... that forward premiums / discounts are purely function of the
interest rate differentials between two countries, whose currencies are
fully convertible. In other words, forward cover
