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2018 (2) TMI 734 - AT - Income TaxAddition treating the premium paid to hedge against exchange fluctuation risk as service fees - Held that:- The appellant has drawn attention to the fact that the similar amounts claimed in the preceding years have been allowed and has also explained in detail that the loan from Bridgestone Corporation Japan was utilized for working capital needs and repayment of existing loans and hence has to be treated as on revenue account and not on capital account and hence as the expenditure was incurred for the purposes of business it was also allowable u/s 37. The claim of the appellant is found to be eligible for allowance in the year under consideration - Decided in favour of assessee. Addition on account of under valuation of closing stock - Held that:- As per section 145A of the Income Tax Act, 1961, wherein method of valuation will be applicable not only in closing stock, but on inventory i.e. opening and closing stock as well as on both purchases and sales. Therefore, the AC is not justified in adding the excise duty in closing stock of raw materials and incidental goods. We, therefore, direct the AO to compute the total income by adding cess, duty or tax paid incurred not only in closing stock but also in purchases, opening stock, sales, wherever such excise duty is already added. In respect of assessment years 2005-06, 2008-09, and 2009- 10, the Ld. CIT(A) has already allowed the claim of the assessee as we have held above. Therefore, on the same reasoning, Departmental appeals for all the three years are dismissed.
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