Tata Consultancy Services Ltd. v. CIT (2019) 178 ITD 51/178 ITD 151 /199 TTJ 716 (Mum.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Method of accounting–Forward contracts-In terms of AS-11, both gains or loss on account of exchange rate fluctuations on reporting date are to be accounted for while computing income chargeable to tax-Revision is held to be valid. [S.145, AS-11]

Assessee-company was engaged in providing information technology services. While computing taxable income, assessee did not include unrealised mark to market gain on open forward contracts in foreign exchange. AO accepted income declared by assessee. Commissioner, however, took a view that assessee should have offered for taxation income from mark to market gain or loss on open forward contracts in foreign exchange on balance sheet date in year in which same had accrued .He passed a revisional order setting aside assessment. On appeal the Tribunal held that in terms of AS-11, both gains or loss on account of exchange rate fluctuations on reporting date are to be accounted for while computing income chargeable to tax. Accordingly the revision order is up held. (AY. 2011 -12)