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TMI Blog2013 (4) TMI 62X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT-I, Baroda dated 31-03-2009 u/s 263 of the I.T. Act. The Ld. AO scrutinized the case u/s 143(3) of the I.T. Act and completed the assessment on 31-10- I.T.A. No.1776/Ahd/2009 A.Y. 2004-05 2006 wherein the gross additions were made at Rs. 3,53,94,191/- and revised loss calculated at Rs. 2,59,31,768/- against return loss of Rs. 6,13,25,959/-. The Ld. A.O. had also allowed carried forward losses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of income by the assessee. The Ld. CIT-DR fairly accepted the facts. We have verified the fact and this interest has already been added back by the appellant in computation of income. Thus, to that extent this order of the AO is not erroneous and prejudicial to the interest of justice. 3. The ld. CIT observed that on perusal of balance sheet liability of a sum of Rs. 8,93,685/- being intere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f opinion which is not permitted under the law as held by the various high courts on this issue. 5. Ground No. 4 is directing to the A.O. that Rs. 6,38,91,300/- being retention amount billed but not due had not accounted by the assessee which has been accepted by the Commissioner of Income-tax by passing the rectification order and allowed the assessee's claim. Thus, the ld counsel for the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r of the A.O. is prejudicial and erroneous to the interest of Revenue. Ld. counsel for the assessee argued that this fluctuation of exchange loss is allowable being a revenue expenditure relied in the case of Woodward Governor Pvt. Ltd. vs. CIT 312 ITR 254(SC) and details were also given before the AO, therefore, there is no revenue loss. We have gone through facts at page no 87 of paper book whic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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