TMI Blog2017 (10) TMI 1416X X X X Extracts X X X X X X X X Extracts X X X X ..... e price of export, which was in US dollar. Therefore, the entire receipts were on revenue account. The Court is of the opinion facially that like in the case of payment towards bank guarantee, interest etc., the outgoings would essentially be covered as operative costs. Admit surviving question as follows: - “Did the Tribunal commit an error in excluding the data in respect of the comparables, i.e., Aptico Ltd., Rights Ltd. and Kitco Ltd. and Apitco Ltd., Kitco Ltd., Tee Consulting Engineers Ltd, Mahindra Consulting Engineers Ltd., Infoedge India Pvt. Ltd. and MMTV Ltd. having regard to the facts and circumstances of the case.” - ITA 419/2016 And ITA 747/2016 - - - Dated:- 23-10-2017 - MR S. RAVINDRA BHAT AND MR SANJEEV SACHDEVA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s enters into forward contract for sale/purchase of Forex to hedge itself from the fluctuation in exchange rates. 44. He observed that the amount of forex loss/gain and hedging cost/premium in each case would depend upon the risk management policy of each company and, therefore, the profit margin at the end of the year may vary substantially from the expected profit margin at the time of entering into project because of fluctuation in the exchange rate and its risk management policy i.e. the extent of which its Forex transactions were hedged. XXX XXX XXX 50. We have considered the rival submissions and have perused t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ally that like in the case of payment towards bank guarantee, interest etc., the outgoings would essentially be covered as operative costs. 5. For these reasons, the Court is of the opinion that no question of law arises on this aspect. 6. The surviving question is as follows: - Did the Tribunal commit an error in excluding the data in respect of the comparables, i.e., Aptico Ltd., Rights Ltd. and Kitco Ltd. (in ITA 419/2016) and Apitco Ltd., Kitco Ltd., Tee Consulting Engineers Ltd, Mahindra Consulting Engineers Ltd., Infoedge India Pvt. Ltd. and MMTV Ltd. (In ITA 747/2016) having regard to the facts and circumstances of the case. 7. Admit. 8. Mr. Satyen Sethi, Advocate accepts notice. 9. List on 18th Januar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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