2015 (8) TMI 54

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..... of Section 80HHC of the Act. See Commissioner of Incometax-I vs. Friends and Friends Shipping Pvt. Ltd. [2013 (5) TMI 458 - GUJARAT HIGH COURT] and Commissioner of Income Tax V. Mitsu Limited [2014 (4) TMI 168 - GUJARAT HIGH COURT], CIT v. Badridas Gauridu (P) Ltd. [2003 (1) TMI 61 - BOMBAY High Court] and CIT v. Soorajmull Nagarmull (1980 (9) TMI 69 - CALCUTTA High Court) with Commissioner of Inc .....

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..... For the Respondent : Mr Swati Soparkar, Adv. JUDGMENT (Per : Honourable Mr. Justice A. J. Desai) 1. While admitting Tax Appeal on 19.09.2007, following substantial questions of law were framed. (1) Whether on the facts and circumstances of the case and in law the Appellate Tribunal was justified in holding that the exchange rate difference to exports made in earlier years was .....

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..... in the case of Commissioner of Income Tax V. Mitsu Limited. By a bipartite hearing on 23.8.2011, Revenues appeal was dismissed. The Court followed the decisions of CIT v. Badridas Gauridu (P) Ltd. reported in 261 ITR 256 and of the Calcutta High Court in the case of CIT v. Soorajmull Nagarmull reported in 129 ITR 169 (Cal.). The said decision was also followed in the order dated 28.3.2013 in the .....

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