Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Nature of loss - Speculative loss or normal business loss - Marked to market loss on hedging of the transaction - The Appellate Tribunal held that speculative transactions are defined as those settled without the actual delivery or transfer of the commodity. The assessee, engaged in the purchase and sale of bullion and manufacturing of gold ornaments, entered into future contracts with suppliers to mitigate potential losses from price fluctuations. The ITAT, after considering precedents and the nature of the assessee's business, concluded that the hedging transactions were essential to its regular business operations and allowed the deduction of the incurred loss u/s 37(1)
Nature of loss - Speculative loss or normal business loss - Marked to market loss on hedging of the transaction - The Appellate Tribunal held that speculative transactions are defined as those settled without the actual delivery or transfer of the commodity. The assessee, engaged in the purchase and sale of bullion and manufacturing of gold ornaments, entered into future contracts with suppliers to mitigate potential losses from price fluctuations. The ITAT, after considering precedents and the nature of the assessee's business, concluded that the hedging transactions were essential to its regular business operations and allowed the deduction of the incurred loss u/s 37(1)
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
