ACIT, Central Circle, Panaji vs. M/S Sociadade De Fomento Industrial P. Ltd, Margao
In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A
…C account and once the income is received, any further loss due to foreign exchange fluctuation is not a revenue expenditure. Reliance was placed on the decision of Delhi High Court in the case of CIT Vs Philips Petroleum International Corporation reported in 272 ITR 355. The AO also relied CBDT Instruction NO.3 of 2010 dated 23.03.2010. 7.1. During appellate proceedings, the AR of the appellant made following written submissions: "The appellant company maintained EEFC Accounts each one of which is maintained with State Bank of India, Vasco and Syndicate Bank, Margao. These accounts are maintained in US Dollar. T…