Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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Unrealised mark-to-market gains on a forward commodity derivative were held not taxable before actual accrual or maturity because income must have really accrued to be brought to tax under mercantile accounting. Applying Woodward Governor and Godhra Electricity, the Court held that fluctuating gains and losses on a forward contract remain notional until expiry, so anticipated gains reflected in accounts do not lose their unrealised character merely due to accounting treatment. The deletion of the addition was upheld, with the clarification that tax consequences on maturity would follow in accordance with law.
Unrealised mark-to-market gains on a forward commodity derivative were held not taxable before actual accrual or maturity because income must have really accrued to be brought to tax under mercantile accounting. Applying Woodward Governor and Godhra Electricity, the Court held that fluctuating gains and losses on a forward contract remain notional until expiry, so anticipated gains reflected in accounts do not lose their unrealised character merely due to accounting treatment. The deletion of the addition was upheld, with the clarification that tax consequences on maturity would follow in accordance with law.
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