Home Highlights July 2014 Year 2014 This

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1. Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the...

2. Admission of income pursuant to survey operation u/s 133A - If the assessee did not adhere to the surrender made during the survey, it was for the AO to bring on record...

3. TP Adjustment - When foreign exchange loss is to form part of the total base of the taxpayer for the purpose of charging a mark up to its AEs as it drives income from...

4. Risk Management and Inter-bank Dealings – Hedging of foreign exchange risk - Circular

5. Hedging of exchange rate risk by Foreign Portfolio Investors (FPIs) under Voluntary Retention Route

6. Nature of loss - speculative transaction - When the assessee is not dealer in foreign exchange and as a part of his normal business activity, enters into hedging...

7. Loss on Forward Contracts in foreign exchange - such transactions were carried out in the normal course of business to guard against the fluctuation in foreign exchange...

8. TP Adjustment - Reduction of economic adjustment on foreign exchange fluctuation loss - in principle, the foreign exchange fluctuation loss adjustment has to be given...

9. Unexplained investments - There is no positive and credible evidence brought on record by the revenue to establish the allegation of cash payment over and above the...

10. Loss in connection with the hedging contract - business loss or speculative loss - For the purpose of hedging the loss due to fluctuation in foreign exchange while...

11. Foreign exchange gain taxability - restatement of foreign currency loan - AO directed to grant deduction of notional exchange loss in the subsequent assessment years - AT

12. Treatment to Forex loss incurred by the assessee on account of derivative transactions as speculative transactions - When the assessee enters into a hedging transaction...

13. Definitions - Regulation 2 of the FOREIGN EXCHANGE MANAGEMENT (FOREIGN EXCHANGE DERIVATIVE CONTRACTS) REGULATIONS, 2000 as amended

14. Foreign investment by Qualified Foreign Investors (QFIs) – Hedging facilities - Circular

15. Speculative loss or not - Determine the nature of losses on forward foreign exchange contracts and foreign exchange derivative contracts - the tribunal found the...