“Commissioner (Appeals)”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(16A) / Section 1174,761 judgments

The decision most relied on for Commissioner (Appeals) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Commissioner (Appeals)

Jute Corporation of India Ltd. v. CIT

187 ITR 688 · 1991 · Supreme Court

1,372

citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)

297 CTR 614 · 2017 · High Court

659

citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT

199 ITR 351 · 1993 · High Court

441

citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate

53 ITR 225 · 1964 · Supreme Court

359

citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

CIT v. Shapoorji Pallonji Mistry

44 ITR 891 · 1962 · Supreme Court

278

citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar

1 SCC 591 · 1985 · Reported

225

citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Mahindra and Mahindra Ltd. v. DCIT

30 SOT 374 · 2009 · ITAT

201

citing judgments

The Commissioner of Income Tax (Appeals) cannot expand the scope of an assessment or improve the Assessing Officer's case in a manner that usurps the revisional power of the Commissioner of Income Tax under Section 263 of the Income-tax Act.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.

56 Taxmann.com 286 · 2015 · High Court

196

citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Judgments citing Commissioner (Appeals)

K D Lite Developers Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, TDS Circle 1(3), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 5325/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Nov 2024AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 194ASection 201Section 201(1)Section 250

requirement to deduct tax at source - In view of assessee's failure to deduct tax at source, Assessing Officer disallowed LC discount charges - Commissioner (Appeals) found that LC discount charges were in nature of reimbursement of cost incurred by suppliers under agreed arrangement and it was also an additional cost ... assessee for purchase of goods - However, no interest payments were made to supplier by assessee – Commissioner (Appeals) thus taking a view that provisions of section 194A were not applicable, deleted disallowance made by Assessing Officer - Tribunal upheld order passed by Commissioner (Appeals) - It was noted that assessee had opened

K D Lite Developers Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, TDS Circle 1(3), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 5305/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Nov 2024AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 194ASection 201Section 201(1)Section 250

DCIT-CC-4(2), Mumbai vs. Shahrukh Khan, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 490/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Nov 2024AY 2012-13

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhan

Section 143(2)Section 14ASection 250Section 271(1)(c)

have considered the rival submissions. Section 271(1)(c) of the Act provides as under: 271. (1) If the Assessing Officer or the Commissioner (Appeals) or the Commissioner in the course of any proceedings under this Act, is satisfied that any person— Page | 4 ITA No. 490/Mum/2024 Shahrukh Khan

DCIT, New Delhi vs. M/S. Thapar Homer Ltd., New Delhi

In the result, the Appeal of the Revenue is dismissed

ITA 6423/DEL/2016[2009-10]Status: DisposedITAT Delhi27 Nov 2024AY 2009-10

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishradcit, Central Circle- M/S. Thapar Homes 15 Limited, B-10, Vs Shivalik, Malviya Nagar, New Delhi- 110017 Pan No:Aaecm0840R (Appellant) (Respondent)

Section 269TSection 271ESection 274Section 275

that proceedings only. In such case where the relevant assessment order or other orders are the subject-matter of an appeal to the Commissioner (Appeals) under Section 246 or an appeal to the Appellate Tribunal under Section 253, after the expiry of the financial year in which the proceedings ... imposition of penalty has been initiated, are completed, or 6 months from the end of the month in which the order of Commissioner (Appeals) or, as the case may be, of the Appellate Tribunal is received by the Chief Commissioner or Commissioner, whichever period expires later. 33. Apparently, Clause

Assistant Commissioner of Income-Tax, Madurai vs. Alba Industries Limited, Chennai

ITA 284/CHNY/2024[2016-17]Status: DisposedITAT Chennai26 Nov 2024AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.282 To 287/Chny/2024 निर्धारणवर्ष/Assessment Years: 2014-15 To 2019-20 & Cross-Objection Nos.20 To 25/Chny/2024 निर्धारणवर्ष/Assessment Years: 2014-15 To 2019-20 The Acit, Central Circle-1, Madurai-625 002. (अपीलार्थी/Appellant) V. M/S. Alba Industries Ltd., No.32/2, Halls Road, Egmore, Chennai-600 008. [Pan: Aabcb 5758 J] (प्रत्यर्थी/Respondent / Objector) Cross- Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement Mr. R. Clement Ramesh Kumar, Cit Mr. S. Sridhar, Advocate 04.09.2024 26.11.2024 आदेश / Order Per Aby T. Varkey, Jm: These Appeals Preferred By The Revenue & The Cross-Objections By The Assessee Are Arising Out Of The Appellate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [In Short 'Cit(A)'] In Relation To The Assessment Orders All Dated 27.08.2021 Passed U/S 143(3)/153A Of The Income-Tax Act, 1961 [In Short `The Act'] For The

Section 132Section 132(4)Section 143(3)Section 153A

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

Assistant Commissioner of Income-Tax, Madurai vs. Alba Industries Limited, Chennai

ITA 282/CHNY/2024[2014-15]Status: DisposedITAT Chennai26 Nov 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.282 To 287/Chny/2024 निर्धारणवर्ष/Assessment Years: 2014-15 To 2019-20 & Cross-Objection Nos.20 To 25/Chny/2024 निर्धारणवर्ष/Assessment Years: 2014-15 To 2019-20 The Acit, Central Circle-1, Madurai-625 002. (अपीलार्थी/Appellant) V. M/S. Alba Industries Ltd., No.32/2, Halls Road, Egmore, Chennai-600 008. [Pan: Aabcb 5758 J] (प्रत्यर्थी/Respondent / Cross- Objector) Department By : Mr. R. Clement Ramesh Kumar, Cit Assessee By : Mr. S. Sridhar, Advocate सुनवाईकीतारीख/Date Of Hearing : 04.09.2024 घोषणाकीतारीख /Date Of Pronouncement : 26.11.2024 आदेश / Order Per Aby T. Varkey, Jm: These Appeals Preferred By The Revenue & The Cross-Objections By The Assessee Are Arising Out Of The Appellate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [In Short 'Cit(A)'] In Relation To The Assessment Orders All Dated 27.08.2021 Passed U/S 143(3)/153A Of The Income-Tax Act, 1961 [In Short `The Act'] For The

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh

Section 132Section 132(4)Section 143(3)Section 153A

Assistant Commissioner of Income-Tax, Madurai vs. Beach Minerals Sands Company, Tirunelveli

ITA 14/CHNY/2024[2014-15]Status: DisposedITAT Chennai26 Nov 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1473 To 1475/Chny/2023 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & Cross-Objection Nos. 28 To 30/Chny/2024 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & आयकर अपील सं./Ita Nos.13 & 14/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15 & Cross-Objection Nos. 26 & 27/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –

Section 132Section 132(4)Section 143(3)Section 153A

following findings of the Hon’ble High Court :- "3. Having perused the assessment order made by the Assessing Officer, the order made by the Commissioner (Appeals) and the Tribunal, we are satisfied that the Tribunal was justified in rejecting the application under section 256(1). It cannot be a matter

Assistant Commissioner of Income-Tax, Madurai vs. Beach Minerals Sands Company, Tirunelveli

ITA 13/CHNY/2024[2013-14]Status: DisposedITAT Chennai26 Nov 2024AY 2013-14

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –

Section 132Section 132(4)Section 143(3)Section 153A

Assistant Commissioner of Income-Tax, Madurai vs. Beach Minerals Sands Company, Tirunelveli

ITA 1474/CHNY/2023[2016-17]Status: DisposedITAT Chennai26 Nov 2024AY 2016-17

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –

Section 132Section 132(4)Section 143(3)Section 153A

Assistant Commissioner of Income-Tax, Madurai vs. Beach Minerals Sands Company, Tirunelveli

ITA 1473/CHNY/2023[2015-16]Status: DisposedITAT Chennai26 Nov 2024AY 2015-16

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –

Section 132Section 132(4)Section 143(3)Section 153A

Income Tax Officer, Ward 1, Ballari vs. Sha Ganeshmal Jewarraj Bohra, Koppal

In the result, both the appeal by the revenue and the CO by the assessee are dismissed

ITA 1202/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Nov 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar S.V., AdvocateFor Respondent: Shri Sridhar E., Jt.CIT(DR)(ITAT), Bengaluru

Section 115BSection 131Section 148Section 68

best judgment assessment under section 144 relying upon the material from the Commercial Tax Department relating to the turnover of the assessee. Before the Commissioner (Appeals), the assessee produced S.T. assessment order for the first time and refused to look into the same on the pretext of additional evidence. Holding ... action of the Commissioner (Appeals) to be unjustified, the Court observed— “10. It is also true that the assessee could have produced the sales-tax assessment order. But here, we are concerned with the propriety and fairness of the estimate made by the ITO, who ventured upon an investigation, which

Anil Kursija, Mumbai vs. ACIT Circle 17(1), Mumbai

In the result, appeal filed by the assessee is allowed for statistical

ITA 4405/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Nov 2024AY 2016-17

Bench: Shri Narendra Kumar Billatya & Shri Raj Kumar Chauhan

Section 138Section 143(3)Section 250Section 51

passed under section 143(3) of the Income Tax Act, 1961 (Act)on 28.12.2018. Being aggrieved, I filed an appeal before the learned Commissioner (Appeals) on 22.01.2019. 2. That, during the pendency of the appeal, I was convicted by the Hon'ble Chief judicial magistrate, o6th court, District Thane ... imprisoned, I could not give attention to the said appeal and instructions due to which the notices remained to be attended and the learned Commissioner (Appeals) passed the ex- parte order under section 250 of the Act on 15.04.2024 confirming the assessment order. 4. That, I was completely clueless about

Bimla, Delhi vs. ITO Ward-38(5), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 7973/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Nov 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekbimla, Vs. Ito, Ward 38 (5), H.No.143, Village Hamidpur, New Delhi. Delhi – 110 036. (Pan : Bpdpb9344B) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Shri Ankit Kumar, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.09.2024 Date Of Order : 26.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-13, New Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 23.07.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Filed Return Of Income Declaring Total Income Of Rs.2,23,030/- On 14.08.2014. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Through Cass & Notices

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR

Section 131Section 143Section 143(2)Section 69

appeal before us raising following grounds of appeal :- “1. On the facts and circumstances of the case and in law, the Learned Commissioner (Appeals) has exceeded its authorities in issuing direction to re-open the assessment of earlier year when the cash credit has taken place. 2. Whether ... contained in section 251(1) of the Act, which reads as under: “251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment; (aa) in an appeal against

Sri Jayalakshmi Rice Mill Contractor G Muralikrishna G vs. Satish & Co, Kaikaluruvs.Income Tax Officer, Ward-1, Bhimavaram

In the result, appeals of the assessee is treated as allowed for statistical purposes

ITA 436/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam25 Nov 2024AY 2021-22

Bench: Shri K. Narasimha Chary & Shri S. Balakrishnan(Through Hybrid Hearing) आ.अपी.सं / Ita No. 436/Viz/2024 (निर्धारण वर्ा / Assessment Year: 2021-22) Sri Jayalakshmi Rice Mill Income Tax Officer, Contractors G Vs. Ward-1, Muralikrishna G V S Bhimavaram-534201. Satish & Co, Kaikaluru-521333, Eluru District. [Pan : Adefs2940Q] अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती‍द्वधरध/Assessee By: Shri K Siva Rama Kumar, Ar रधजस्‍व‍द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई‍की‍तधरीख/Date Of Hearing: 19/11/2024 घोर्णध की‍तधरीख/Pronouncement On: 25/11/2024

For Appellant: Shri K Siva Rama Kumar, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 250Section 250(6)

evidence to substantiate the grounds raised. 6. Requirement of law under section 250 (6) of the Act is that the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision. Even

Income Tax Officer, Esplanade Aayakar Bhavan vs. Alert Consultants and Credit Pvt Ltd, R N Mukherjee Road

In the result, the appeal of the revenue stands dismissed

ITA 1085/KOL/2023[2012-13]Status: DisposedITAT Kolkata25 Nov 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

Section 250

provides for power to the CIT(A) to give direction to the Assessing Officer. The section reads as under: “(4) The Joint Commissioner (Appeals) or the Commissioner (Appeals) may, before disposing of any appeal, make such further inquiry as he thinks fit, or may direct the Assessing Officer to make ... further inquiry and report the result of the same to the Joint Commissioner (Appeals) or the Commissioner (Appeals).” The powers of CIT(A) under section 250(4) are discretionary power and not the mandatory power. The section reads that the CIT(A) “may” before disposing off appeal which means

Sri. Basavana Mathikere Betaswamy Gowda Ramaswamy Gowda, Bangalore vs. Income Tax Officer, Ward-2(2)(2), Bangalore

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

ITA 1313/BANG/2024[2009-10]Status: DisposedITAT Bangalore25 Nov 2024AY 2009-10

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2009-10

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri V Parithivel, JCIT (DR)

Section 271(1)(C)Section 271(1)(c)Section 274

Taxmann.com 248 has held as under: 5. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) as well as the ITAT have categorically held that in the present case, there is no record of satisfaction by the Assessing Officer that there

Steel City Beverages Limited, New Delhi vs. ITO, Ward-24(1), New Delhi

In the result the appeal of the assessee ispartly allowed for statistical purpose

ITA 3133/DEL/2023[2018-19]Status: DisposedITAT Delhi25 Nov 2024AY 2018-19

Bench: Sh.M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2018-19 Steel City Beverages Vs Ito Limited, C/O Advocate Ward- 24 (1) Kanika Jain D-80, Lgf New Delhi Panchsheel New Delhi - 1110017 Pan No.Aaccs3967M (Appellant) (Respondent)

Section 142Section 143Section 143(2)Section 143(3)Section 36Section 40Section 40ASection 47A(7)

paid by them to the assessee's employees at the time of their respective retirement and therefore, he disallowed its claim. On appeal, the Commissioner (Appeals) held that there was no actual termination of the services of the employees and the discharge of the liability in question was capital

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Venus Infrastructure and Developers Private Limited, Ahmedabad

In the result, the grounds raised by the Revenue is devoid of merits and the same is hereby dismissed

ITA 106/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2018-19

Bench: Ld. Cit(A) Who Followed Jurisdictional High Court Judgement In Assessee’S Own Case For The A.Y. 2012-13 Which Was Confirmed By The Hon’Ble Supreme Court Reported In 152 Taxmann.Com 456 (Sc) Deleted The Addition By Observing As Follows:-

For Appellant: Shri Parimalsinh B. Parmar, A.R. &For Respondent: Smt. Trupti Patel, Sr. D.R

Section 143(3)Section 80I

Assessing Officer disallowed said claim on ground that assessee had not gotten BU permission for entire project upto 31-3- 2012 Commissioner (Appeals allowed claim of assessee on ground that delay was caused due to dispute of jurisdiction between AMC and AUDA over issuance of BU permission and after resolution ... same AMC issued permission before due date of 21-3-2012 Tribunal upheld order of Commissioner (Appeal) Whether no error committed by Tribunal in affirming order passed by Commissioner (Appeals)- Held, yes [Para 13] [In favour of assessee]” 6.5 It is also important to mention here that

ACIT-3(4), Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the appeal of the assessee is allowed

ITA 2898/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Respondent: Mr. Madhur Agrawal

Section 14ASection 271(1)(c)Section 32A

machinery, qua which foreign currency fluctuation loss had been incurred. [Para 17.3] The record shows that the assessee had preferred the appeal with the Commissioner (Appeals) only vis-a-vis that aspect of the assessment order whereby depreciation had not been granted by the Assessing Officer. [Para 19] Reliance Industries ... Furthermore, as noted by the Commissioner (Appeals) while dealing with the penalty order passed by the Dy. Commissioner, there was in fact no advantage accruing to the assessee in claiming foreign currency fluctuation loss as deductible expenditure, given the fact that it had unobserved losses amounting

Reliance Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax -Circle 3(4), Mumbai

ITA 2767/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Madhur AgrawalFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 14ASection 271(1)(c)Section 32A

machinery, qua which foreign currency fluctuation loss had been incurred. [Para 17.3] The record shows that the assessee had preferred the appeal with the Commissioner (Appeals) only vis-a-vis that aspect of the assessment order whereby depreciation had not been granted by the Assessing Officer. [Para 19] Furthermore ... noted by the Commissioner (Appeals) while dealing with the penalty order passed by the Dy. Commissioner, there was in fact no advantage accruing to the assessee in claiming foreign currency fluctuation loss as deductible expenditure, given the fact that it had unobserved losses amounting to Rs. 12,218.52 crores.[Para