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    <title>2021 (3) TMI 434 - KARNATAKA HIGH COURT</title>
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    <description>Hedging loss on foreign exchange forward contracts was treated as deductible business loss, not a speculative or contingent loss, because the contracts were entered to hedge export proceeds, the liability had accrued, and the year-end revaluation reflected a reasonably ascertainable obligation. The court also held that section 14A read with Rule 8D could not be applied where no exempt dividend income had been earned in the relevant year, and the contrary view in an earlier decision could not be followed to that extent. The Revenue&#039;s appeal therefore failed, and the assessee&#039;s claims were accepted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=405106</link>
      <description>Hedging loss on foreign exchange forward contracts was treated as deductible business loss, not a speculative or contingent loss, because the contracts were entered to hedge export proceeds, the liability had accrued, and the year-end revaluation reflected a reasonably ascertainable obligation. The court also held that section 14A read with Rule 8D could not be applied where no exempt dividend income had been earned in the relevant year, and the contrary view in an earlier decision could not be followed to that extent. The Revenue&#039;s appeal therefore failed, and the assessee&#039;s claims were accepted.</description>
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