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2018 (3) TMI 1814 - AT - Income TaxDetermination of PLI - Dispute Resolution Panel directing AO to exclude the expenses pertaining to earlier year for computation of the PLI of the year under consideration as the same pertains to earlier year and not forming expenditure of this year - whether prior period expenses were operating cost and the same had to be included or excluded while computing PLI for the year under consideration? - HELD THAT:- We find no merit in the issue raised by the Revenue in this regard. DRP has directed vide para 2.4.1 to exclude earlier year expenses for determining PLI of the year under appeal. We find similar issue arose before the Tribunal in ACIT Vs. Dana India Technical Centre Pvt. Ltd. [2016 (5) TMI 631 - ITAT PUNE] hold that while computing PLI for the year under consideration, the loss arising on account of foreign exchange fluctuation is to be excluded. However, the loss arising on account of export proceeds realized from exports of relevant year are to be considered while computing PLI of the assessee. In view thereof, we modify the order of CIT(A) and direct the Assessing Officer to re-compute the PLI in the hands of assessee and foreign exchange fluctuation losses of the earlier years are to be kept out of calculation of PLI for the year under consideration. - Decided against revenue
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