Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (8) TMI 1700 - ITAT CHENNAITP Adjustment - customs duty adjustment while computing Arm’s Length Price (ALP) - HELD THAT:- As similar issue came for consideration before this Tribunal in assessee's own case [2017 (1) TMI 1690 - ITAT CHENNAI] direct the A.O. to give suitable adjustment against the custom duty component while determining the ALP. Non-granting of working capital adjustment while computing the ALP - HELD THAT:- As the similar issue came for consideration before this Tribunal in assessee's own case[2017 (1) TMI 1690 - ITAT CHENNAI] there is necessity for working capital adjustment and accordingly we remit the issue to the file of AO to consider the material for fresh consideration. Treating foreign exchange loss suffered by the assessee as operating expense - Whether TPO erred in treating the entire foreign exchange loss suffered by the assessee as operating expense? - HELD THAT:- As in the present case as rightly pointed out by the ld.D.R that earlier year the assessee claimed foreign exchange loss as operating expenditure. This year assessee has shifted its stand and claimed it as non operating expenditure. There is no consistency in its approach and also no reason has been given for such a change. Being so, in our opinion, foreign exchange loss is to be treated as operating nature only. Hence, this ground is dismissed.
|