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    <title>2018 (12) TMI 1328 - ITAT MUMBAI</title>
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    <description>Jurisdictional objection failed because the record did not show a completed transfer of assessment jurisdiction before the order, and allocation of functions between income-tax authorities remained an administrative matter. Securities held as trading assets were treated as business stock, so year-end mark-to-market diminution and realised loss on sale were allowable business deductions on the cost-or-market, whichever is lower, basis. Interest on securities was not taxable on accrual before the contractual due date for payment, as no accrual arose merely through time apportionment. The assessee therefore succeeded on the substantive issues, while the revenue&#039;s appeals were rejected.</description>
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      <description>Jurisdictional objection failed because the record did not show a completed transfer of assessment jurisdiction before the order, and allocation of functions between income-tax authorities remained an administrative matter. Securities held as trading assets were treated as business stock, so year-end mark-to-market diminution and realised loss on sale were allowable business deductions on the cost-or-market, whichever is lower, basis. Interest on securities was not taxable on accrual before the contractual due date for payment, as no accrual arose merely through time apportionment. The assessee therefore succeeded on the substantive issues, while the revenue&#039;s appeals were rejected.</description>
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