Reimbursement of Forex Loss Not Taxable Due to Capital Nature

Informatica Business Solutions Pvt Ltd Vs JCIT (ITAT Bangalore)

Reimbursement of ECB Forex Loss Not Taxable u/s 28(iv); s.40(a)(iii) Issue Remanded; Reversal of Earlier-Disallowed Provision Cannot Be Taxed

Assessee, a wholly-owned subsidiary of Informatica Corp, provides Software Development, ITeS & Marketing Support services to AE. Draft assessment u/s 143(3) r.w.s 144C included TP adjustment of ₹120.28 Cr (later withdrawn from appeal via MAP), &  three non-TP additions:

(1) ₹4,88,45,724 taxed u/s 28(iv) as be

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