https://www.taxtmi.com/caselaws?id=181580 Contracts settled without actual delivery are treated as speculative transactions under the 1922 Income-tax Act, even if delivery was initially intended. The statutory scheme distinguishes speculative business from other business and limits the set-off of speculative losses to speculative profits only. Accordingly, losses from such settlement contracts cannot be adjusted against profits from non-speculative business transactions. The rule turns on the mode of settlement, not on the parties' original intention to deliver, and operates as a substantive restriction on the general set-off provision. en-us Thu, 13 Sep 1962 00:00:00 +0530 Wed, 20 Apr 2016 11:01:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181580 Contracts settled without actual delivery are treated as speculative transactions under the 1922 Income-tax Act, even if delivery was initially intended. The statutory scheme distinguishes speculative business from other business and limits the set-off of speculative losses to speculative profits only. Accordingly, losses from such settlement contracts cannot be adjusted against profits from non-speculative business transactions. The rule turns on the mode of settlement, not on the parties' original intention to deliver, and operates as a substantive restriction on the general set-off provision. Case-Laws Income Tax Thu, 13 Sep 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181580