TMI Blog2023 (1) TMI 72X X X X Extracts X X X X X X X X Extracts X X X X ..... t [ 2017 (9) TMI 248 - BOMBAY HIGH COURT] were held against the Revenue with respect to the earlier assessment years 2005-2006 2009-2010. The matter has not been carried further by the Revenue. In that view of the matter, no error has been committed by the ITAT and/or even the High Court. Hence, the present Special Leave Petition stands dismissed. Losses due to foreign exchange fl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... export commission - It is required to be noted that there are concurrent findings recorded that the foreign entity receiving the amounts were not Indian residents and subject to tax and that the services rendered were rendered outside India, neither the ITAT nor the High Court have committed any error in holding the said issue against the Revenue. - Petition(s) for Special Leave to Appeal (C) N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , by which the High Court has dismissed the said Appeal preferred by the Revenue and has concurred with the decision of the Income Tax Appellate Tribunal [ITAT], the Revenue has preferred the present Special Leave Petition. We have gone through the judgment and order passed by the ITAT as well as the impugned judgment and order passed by the High Court. It appears that both the issues raised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ort commission. Insofar as the first issue, namely, losses due to foreign exchange fluctuation on the export proceeds is concerned, the issue is covered by the decision of this Court in the case of CIT vs. Woodward Governor India (P) Ltd. vs. (2009) 312 ITR 254 (SC). Mr. N. Venkatraman, learned ASG, is not in a position to dispute the above. Under the circumstances, it cannot be said that t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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