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    <title>2025 (6) TMI 1761 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad allowed the assessee&#039;s appeal on multiple grounds. The tribunal held that commodity transactions were not speculative as they involved actual delivery and were not conducted on NSEL platform. Future and option transactions were deemed business losses under Section 43(5) proviso as they were undertaken to hedge existing stock in the assessee&#039;s manufacturing business. Interest capitalization depreciation was allowed, and prior period income addition was deleted after verification of revised computation and tax payment. The tribunal confirmed that purchases of cotton wash oil and mustard seeds totaling Rs. 80.51 crores were genuine with payments made through banking channels and NSEL settlement accounts. Additional depreciation disallowance was also deleted following the Godrej Industries precedent, recognizing it as a one-time industrialization benefit claimable across assessment years.</description>
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    <pubDate>Mon, 23 Jun 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=773648</link>
      <description>The ITAT Ahmedabad allowed the assessee&#039;s appeal on multiple grounds. The tribunal held that commodity transactions were not speculative as they involved actual delivery and were not conducted on NSEL platform. Future and option transactions were deemed business losses under Section 43(5) proviso as they were undertaken to hedge existing stock in the assessee&#039;s manufacturing business. Interest capitalization depreciation was allowed, and prior period income addition was deleted after verification of revised computation and tax payment. The tribunal confirmed that purchases of cotton wash oil and mustard seeds totaling Rs. 80.51 crores were genuine with payments made through banking channels and NSEL settlement accounts. Additional depreciation disallowance was also deleted following the Godrej Industries precedent, recognizing it as a one-time industrialization benefit claimable across assessment years.</description>
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