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2014 (1) TMI 1257 - AT - Income TaxWhether profit on foreign exchange be included in export turnover - Held that:- Decision in Sutlej Cotton Mills Ltd. v. CIT [1978 (9) TMI 1 - SUPREME Court] followed - Where profit or loss arises to an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into another currency, such profit or loss would ordinarily be trading profit or loss if the foreign currency is held by the assessee on revenue account or as a trading asset or as part of circulating capital embarked in the business - If the foreign currency is held as a capital asset or as fixed capital, such profit or loss would be of capital nature - The foreign exchange gain was income derived by export business of the assessee, and, eligible for deduction u/s 10A of the Act - Decided in favour of assessee. Whether telecommunication and traveling expenses be included in total turnover for deduction u/s 10A - Held that:- Decision in ITO v. M/s. Sak Soft Ltd [2009 (3) TMI 243 - ITAT MADRAS-D] followed - The CIT (A) is justified in excluding the expenditure incurred towards freight, telecommunication charges etc., by company from both export turnover and total turnover for the purposes of deduction u/s 10A of the Act - Decided in favour of assessee.
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