Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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 
of 4805
Join Channel
TaxTMI 
