Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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