CIT v. Woodward Governor India Pvt. Ltd.

312 ITR 254Supreme Court of India2009#45 most cited

What is CIT v. Woodward Governor India Pvt. Ltd. authority for?

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

968

judgments rely on this decision, according to BharatTax’s citation analysis of 371,887 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. Woodward Governor · 312 ITR 254 · Section 37(1) · Section 43A · Section 145(3) · foreign exchange fluctuation · mercantile system of accounting · stock valuation · closing stock · revenue expenditure

Also reported as

21 DTR 106

Sections most often in play

Section 37(1)Section 143(3)Section 14ASection 115JBSection 147Section 142(1)Section 43(5)Section 40(a)(ia)
Read the full judgment

Issues it is cited on

section 43asection 40(a)(i)mercantile system of accountingbook profitssection 37(1)section 115jrevenue expendituresection 43capital expendituresection 40(a)section 115jbsection 32

Judgments citing CIT v. Woodward Governor India Pvt. Ltd.

M/S. Housing & Urban Development Corporation Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 3305/DEL/2017[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…ed the expenditure booked as foreign exchange fluctuation expenses amounting to Rs. 40,28,39,290/- on the ground that these are notional losses. The ld. CIT(A), following the decision of the hon’ble Supreme Court in the case of Woodward Governor India P Ltd 312 ITR 254 (SC), allowed the loss as expense. 18. We have heard the rival submissions and have perused the relevant material on record. We find that the ld. CIT(A) gave a categorical finding that notional expenses are booked under this head at the end of every quarter in accordance with the Accounting Standard 21 while finalizing quarterly results but…

Assistant Commissioner of Income Tax, Circle 2(1)(1), Vadodara, Race Course vs. Unimed Technologies Limited, Halol

ITA 632/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

…97,16,443/- were incurred in relation to acquisition of capital goods and hence liable to be capitalised in accordance with section 43A of the Act and judicial precedents including the Supreme Court judgment in CIT v. Woodward Governor India (P.) Ltd. [(2009) 312 ITR 254 (SC)]. Adding the above to the assessee's own suo motu capitalisation of Rs.20,71,664/-, the AO held that the total capital loss on account of foreign currency fluctuation and related bank charges amounted to Rs.3,17,88,107/-. The AO disallowed the same as inadmissible under section 37(1), holding that these were capital in nature. 17.2 Based on…

Unimed Technologies Limited, Panchmahal vs. The ACIT, Circle-2(1)(1), Vadodara

ITA 623/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2016-17 Unimed Technologies Limited Acit, Cir.2(1)(1) Survey No.22 & 22, Vs. Vadodara. Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B Asstt.Year : 2016-17 Acit, Cir.2(1)(1) Unimed Technologies Limited Vadodara. Vs. Survey No.22 & 22, Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 17/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

…97,16,443/- were incurred in relation to acquisition of capital goods and hence liable to be capitalised in accordance with section 43A of the Act and judicial precedents including the Supreme Court judgment in CIT v. Woodward Governor India (P.) Ltd. [(2009) 312 ITR 254 (SC)]. Adding the above to the assessee’s own suo motu capitalisation of Rs.20,71,664/-, the AO held that the total capital loss on account of foreign currency fluctuation and related bank charges amounted to Rs.3,17,88,107/-. The AO disallowed the same as inadmissible under section 37(1), holding that these were capital in nature. ITA No.623 an…

M/S Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 5358/DEL/2010[2006-07]Status: DisposedITAT Delhi16 Jul 2025AY 2006-07

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has fa…

Gujrat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 4856/DEL/2010[2004-05]Status: DisposedITAT Delhi16 Jul 2025AY 2004-05

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singhsl.No. Ita No. Filed By Assessee/Revenue Assessment Year Authority Passing The Order

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has fa…

ACIT, New Delhi vs. M/S Gujarat Guardian Ltd., New Delhi

ITA 4791/DEL/2010[2004-05]Status: DisposedITAT Delhi16 Jul 2025AY 2004-05

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 159/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 158/DEL/2010[2002-03]Status: DisposedITAT Delhi16 Jul 2025AY 2002-03

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

DCIT, New Delhi vs. M/S. Gujrat Guardian Ltd., New Delhi

ITA 157/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

DCIT, New Delhi vs. M/S Gujrat Guardian Ltd., New Delhi

ITA 4859/DEL/2009[2002-03]Status: DisposedITAT Delhi16 Jul 2025AY 2002-03

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground of appeal of the assessee. 17. The next issue in the assessee's appeal is the disallowance of Rs.10,67,000/- being doubtful debts written off as irrecoverable by the assessee during the relevant assessment year. The case of the AO is that the assessee has made a mere provision of the doubtful debts and has f…

Anunta Technology Management Services Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2407/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailanunta Technology Management Services Ltd., Level – 2, Block – 6, Nirlon Knowledge Park, Goregaon East, S.O. Mumbai ............... Appellant Mumbai - 400063 Pan : Aakca6159M V/S Dcit – 4(1)(1), ……………… Respondent Mumbai Assessee By : Shri K.K. Ved Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

For Appellant: Shri K.K. VedFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 263Section 37(1)

…heir services, which is nothing but an expenditure u/s 37(1) of the Act. 9.2.8 Though discount on premium is nothing but an expenditure u/s 37(1), it is worth noting that the Hon'ble Supreme Court in the case of CIT v. Woodward Governor India (P.) Ltd. [2009] 312 ITR 254/179 Taxman 326 has gone to the extent of covering "loss" in certain circumstances within the purview of "expenditure" as used in section in 37(1). In that case, the assessee incurred 10 additional liability due to exchange rate fluctuation on a revenue account. The Assessing Officer did not allow deduction u/s 37. When the matter finally reached…

M/S. Ntpc Limited, New Delhi vs. Addl.CIT, New Delhi

In the result, the appeal of the assessee as recalled vide MA No

ITA 4083/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri Manish Agarwalntpc Limited, Addl. Cit, Core-7, Scope Complex-7, Range-13, Institutional Area, Vs. New Delhi-110002. Lodi Road, New Delhi-110003. Pan:Aaacn0255D (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Department By Shri Shankar Lal, Sr. Dr Date Of Hearing 28.04.2025 Date Of Pronouncement 18.06.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax (Appeals)-16, Delhi [The Cit(A) In Short] In Appeal No. 214/10-11 Dated 28.04.2014 For A.Y. 2008-09 Passed U/S 250 Of The Income Tax Act, 1961 (“The Act” In Short).

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER NTPC Limited, Addl. CIT, Core-7, Scope Complex-7, Range-13, Institutional Area, Vs. New Delhi-110002. Lodi Road, New Delhi-110003. PAN:AAACN0255D (Appellant) (Respondent) Assessee by Shri Ved Jain, Adv. and Ms. Uma Upadhyay, CA Department by Shri Shankar Lal, Sr. DR Date of hearing 28.04.2025 Date of pronouncement 18.06.2025 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the order passed by the Commissioner of Income Tax (Appeals)-1…

Shah Brothers, Chaibasa vs. ACIT Central Circle-1, Ranchi

In the result, this appeal of the assessee is allowed

ITA 134/RAN/2023[2013-14]Status: DisposedITAT Ranchi10 Jun 2025AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayshah Brothers, A.C.I.T., Thana Lane, Chaibasa-833201 Central Circle-1, Vs. (Jharkhand) Ranchi. Pan No. Aazfs 7498 F Appellant/ Assessee Respondent/ Revenue

Section 143(3)

…ve perused the order passed by the learned Tribunal and we find that the learned Tribunal rightly took note of the legal position and granted relief by referring to the order passed by the Hon'ble Supreme Court in CIT Vs Woodward Governor India P. Ltd. (2009) 312 ITR 254 (SC) and the decision in Oil and Natural Gas Corporation Ltd. Vs CIT 322 ITR 180 (SC). Identical issue was considered by this Court in the case of Principal Commissioner of Income Tax-1, Kolkata Vs M/s Price Waterhouse Coopers Pvt. Ltd. in ITAT 269 of 2017 dated 17th December, 2021 and the issue was decided in favour of the assessee. Similar was…

Icici Bank Ltd, Mumbai vs. Addl CIT RG 3 (1), Mumbai

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

…view consequent effect of this accounting treatment is 31 to recognized as exchange fluctuation gain or loss in the profit and loss account as on the valuation date. Hon'ble Supreme Court in case of CIT vs Woodward Governor India (P) Ltd., reported in (2009) 312 ITR 254. Hon'ble Supreme Court established a precedent regarding the tax treatment of foreign exchange losses on both revenue and capital account transactions. Hon'ble Court held that, transaction in which a legal liability is incurred before it is actually disbursed, would be regarded as revenue in nature. In the present facts of the case, assessee incu…

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

…reatment is 29 ITA No.4249 & 4159/Mum/2014 ICICI Bank Ltd. to recognized as exchange fluctuation gain or loss in the profit and loss account as on the valuation date. Hon'ble Supreme Court in case of CIT vs Woodward Governor India (P) Ltd., reported in (2009) 312 ITR 254. Hon'ble Supreme Court established a precedent regarding the tax treatment of foreign exchange losses on both revenue and capital account transactions. Hon'ble Court held that, transaction in which a legal liability is incurred before it is actually disbursed, would be regarded as revenue in nature. In the present facts of the case, assessee incu…

Niho Construction Ltd., New Delhi vs. ITO, Ward- 18(2), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3676/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Apr 2025AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2007-08] Acit, Vs M/S. Nuwave E Solutions (P) Circle-13(1), Ltd., 3Rd Floor, District Centre, New Delhi Dda Building, Nehru Place, New Delhi. Pan-Aabcn5790Q Appellant Respondent Appellant By Shri Pravin Rawal, Cit Dr Respondent By Dr. Rakesh Gutpa, Adv., Shri Saksham Agarwal, Ca, Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Date Of Hearing 26.06.2025 Date Of Pronouncement 12.09.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Revenue Against The Order Dated 15.03.2011 Passed By Ld. Commissioner Of Income Tax (Appeal)-Xvi, New Delhi [“Cit(A)”, In Short] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 31.12.2010 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2007-08. 2. Brief Facts Of The Case Are That Assessee Is A Company & E- Filed Its Return Of Income On 30.08.2007, Declaring Total Income Of Inr 1,45,48,453/-. The Said Return Was Revised On 20.08.2008, Declaring The Same Income As Was Declared The Return Of Income Filed U/S 139(1). The Case Of The Assessee Was Selected For Scrutiny & Various Queries Were Raised Which Were Replied By The Assessee. The Assessee Is Engaged In The Business Of Development & Export Of Software & 100% Eou Registered With Director Software Technology Park Of India In Terms Of Registration Certificate Dated 31.03.1999. The Major Shareholder In The Assessee Company Is Shri Anil Gutpa Who Is Having 99% Shareholding & Is Taking Substantial Interest In Day-To-Day Affairs Of The Assessee & Also In Its Associate Enterprises (“Ae”) At Us Who Is The Sole Buyer Of The Software Developed By The Assessee.

Section 10Section 10ASection 139(1)Section 143(3)Section 250Section 40Section 801A

…his findings that foreign exchange fluctuation gain is income from software export and eligible for exemption u/s 10A by placing reliance on various judgements including the judgements of Hon’ble Supreme Court in the case of CIT v/s. Woodward Governor P Ltd. 312 ITR 254.(SC) and further ton he decision of coordinate bench of Tribunal in the case of CIT v/s. Sony India Pvt. Ltd. [2009] 315 ITR (A.T.) 0150- [ITAT-Delhi). The relevant observations of Ld. CIT(A) in para 4.3 are as under:- 4.3. “I have considered the assessment order, written submissions filed by the counsel and judicial pronouncements as relied upon…

Commissioner of Income Tax-II vs. Gland Pharma Ltd

ITTA/96/2017HC Telangana09 Apr 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

M/S Deora Electric Works, Allahabad vs. Jt.CIT, Allahabad

In the result, the appeal of the assessee is partly allowed

ITA 637/ALLD/2014[2010-11]Status: DisposedITAT Allahabad20 Mar 2025AY 2010-11

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2010-11 M/S Deora Electric Works V. The Jcit 58-A, Sardar Patel Marg Range – I Allahabad Allahabad Pan:Aadfd7479B (Appellant) (Respondent) Appellant By: Shri Praveen Godbole, C.A. Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 17 01 2025 Date Of Pronouncement: 20 03 2025 O R D E R

For Appellant: Shri Praveen Godbole, C.AFor Respondent: Shri A. K. Singh, Sr. D.R
Section 143(3)Section 145(3)Section 250

…be shown in the balance sheet without routing the same through the profit and loss account. He upheld the decision of the Assessing Officer to rely upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Wood Word Governor India Pvt. Ltd. (2009) 312 ITR 254 (SC), in which it has been held that the income has to be declared on due basis, even before it is actually received. Therefore, he confirmed the addition of Rs.56,69,837/- made by the Assessing Officer. On the issue of rejection of the books of account, the ld. CIT(A) observed that different ITAT Benches in the cases of Goyal Construction Compan…

Vgm Export, Vasco vs. Joint Commissioner of Income Tax, Margao

ITA 114/PAN/2023[2010-11]Status: DisposedITAT Panaji25 Feb 2025AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 114/Pan/2023 Assessment Year : 2010-11 Vgm Export Suvarn Bandekar Building, Swatantra Path, Vasco, Goa Pan : Aaafv6197P . . . . . . . Applicant V/S Joint Commissioner Of Income Tax, Margao Range, Margao. . . . . . . . Respondent Appearances Assessee By : Mr P B Deshpande [‘Ld. Ar’] Revenue By : Mr Ravindra Hattalli [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 20/02/2025 घोषणा की तारीख / Date Of Pronouncement : 25/02/2025

For Appellant: Mr P B Deshpande [‘Ld. AR’]For Respondent: Mr Ravindra Hattalli [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 250Section 40

…m, is claimed as allowable business deduction u/s 37(1) of the Act. This claim of the assessee for deduction finds support in the decision of Hon’ble Apex Court rendered in the case of ‘CIT Vs M/s Woodward Governor India Pvt Ltd.’ [2009, 179 Taxman 326 (SC) & 312 ITR 254 (SC)]. 5. To brace the allowability of deduction the Ld. Mr Deshpande further submitted that, it must be noted that, there was no explicit provision in the Act for deductibility of exchange loss, until following settled position of law laid in ‘M/s Woodward Governor India Pvt Ltd.’ (supra), the legislature by Finance Act 2018 brought in a novel…