https://www.taxtmi.com/caselaws?id=445184 ITAT Delhi allowed assessee's claim for mark to market losses on unrealized foreign exchange forward contracts. AO had disallowed the losses treating them as contingent and notional in nature since contracts had not crystallized. ITAT held that such losses are not notional or contingent but crystallize at year-end despite contracts continuing into next year. Decision supported by SC precedent in Woodward Governor India case and coordinate bench decisions. ITAT noted assessee's consistent accounting treatment, offering corresponding gains in subsequent year for taxation per ICAI standards. Loss treated as ordinary business loss, not provisional. CIT(A)'s order allowing the deduction was upheld. en-us Mon, 16 Oct 2023 00:00:00 +0530 Wed, 01 Nov 2023 09:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445184 ITAT Delhi allowed assessee's claim for mark to market losses on unrealized foreign exchange forward contracts. AO had disallowed the losses treating them as contingent and notional in nature since contracts had not crystallized. ITAT held that such losses are not notional or contingent but crystallize at year-end despite contracts continuing into next year. Decision supported by SC precedent in Woodward Governor India case and coordinate bench decisions. ITAT noted assessee's consistent accounting treatment, offering corresponding gains in subsequent year for taxation per ICAI standards. Loss treated as ordinary business loss, not provisional. CIT(A)'s order allowing the deduction was upheld. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445184