Challenged tax appeal on forward exchange loss dismissed for lack of substantial legal questions.

The appeal challenged the Income Tax Appellate Tribunal's order regarding the "Mark to Market" loss on a forward exchange contract revaluation. The court dismissed the appeal as it found that the issues raised did not give rise to any substantial question of law. The first issue regarding the allowance of the loss was not entertained as it was considered settled in previous court decisions. The second issue concerning non-uniformity of revaluation rates for debtors and compliance with AS-11 guidelines was not raised before the Tribunal and thus was also not entertained. Consequently, the Income Tax Appeal was dismissed.

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Issues Involved:
1. Interpretation of "Mark to Market" loss on revaluation of forward exchange contract.
2. Non-uniformity of rates of revaluation for debtors and adherence to AS-11 guidance on currency rates.

Analysis:
1. The appeal challenged the Income Tax Appellate Tribunal's order regarding the "Mark to Market" loss on a forward exchange contract revaluation. The first question of law was whether this loss was allowable. The counsel for the Revenue argued that the issue had been settled in favor of the Assessee in previous court decisions. Citing specific cases, it was contended that the matter was already concluded, and hence, no substantial question of law arose. Consequently, this question was not entertained, leading to the dismissal of the appeal.

2. The second question pertained to the non-uniformity of revaluation rates for debtors and compliance with AS-11 guidelines on currency rates. The court observed that this issue was not raised before the Tribunal during the proceedings, as it was not mentioned in the impugned order. As a result, since the question did not arise from the Tribunal's decision, it was also not entertained. Consequently, both questions were deemed not to give rise to any substantial question of law, leading to the dismissal of the Income Tax Appeal.

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