Case Law Details
Corteva Agriscience Services India Pvt. Ltd. Vs DCIT (ITAT Hyderabad)
ITAT Hyderabad held that revision under section 263 of the Income Tax Act justified as consistency not followed in treatment of foreign exchange gain/loss amounts to error in sofar as it is prejudicial to the interest of revenue.
Facts- Subsequent to the assessment, PCIT issued notice under section 263 of the Act proposing to visit the issue relating to the assessee treating the foreign exchange loss as operating. Notably, the assessee reiterated their stand and also pleaded that there was detailed investigation by TPO and, therefore, no revision of order could be done.
CIT(IT&TP) not considering the nature of the foreign exchange loss in the light of the consistent accounting treatment given by the statutory auditors for the earlier and subsequent years, makes the assessment order erroneous insofar as prejudicial to the interest of Revenue. CIT(IT&TP), therefore, set aside the assessment order.
Being aggrieved, the present appeal is filed.
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