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Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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)
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