https://www.taxtmi.com/caselaws?id=770223 ITAT Ahmedabad allowed assessee's appeal against CIT's revision order u/s 263. CIT had found AO's allowance of foreign currency derivative transaction losses erroneous, treating them as notional marked-to-market losses prohibited under CBDT Instruction 3/2010. ITAT held CIT misappreciated facts - losses were settled losses on exchange differences for outstanding creditors (allowable under AS-11 and Supreme Court precedents) and actual losses on forward contracts, not M2M losses. CIT's alternative application of section 73 explanation was incorrect as it applies only to share trading, not foreign currency transactions. Revision order unsustainable due to factual misappreciation and violation of natural justice principles. en-us Thu, 16 Jan 2025 00:00:00 +0530 Tue, 06 May 2025 18:55:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770223 ITAT Ahmedabad allowed assessee's appeal against CIT's revision order u/s 263. CIT had found AO's allowance of foreign currency derivative transaction losses erroneous, treating them as notional marked-to-market losses prohibited under CBDT Instruction 3/2010. ITAT held CIT misappreciated facts - losses were settled losses on exchange differences for outstanding creditors (allowable under AS-11 and Supreme Court precedents) and actual losses on forward contracts, not M2M losses. CIT's alternative application of section 73 explanation was incorrect as it applies only to share trading, not foreign currency transactions. Revision order unsustainable due to factual misappreciation and violation of natural justice principles. Case-Laws Income Tax Thu, 16 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770223