https://www.taxtmi.com/caselaws?id=773889 A loss arising from fraudulent securities transactions, where no securities were received against the amount paid, was treated as a business loss incidental to business rather than a capital loss. The applicable principle was that a fraud or embezzlement loss becomes allowable in the year it is discovered or crystallises, when recovery is no longer reasonably expected; the claim was therefore allowable in the relevant year and the disallowance was deleted. Because the penalty under section 271(1)(c) rested only on that deleted addition, the penalty also ceased to survive and was deleted. en-us Wed, 25 Jun 2025 00:00:00 +0530 Sat, 28 Jun 2025 10:12:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773889 A loss arising from fraudulent securities transactions, where no securities were received against the amount paid, was treated as a business loss incidental to business rather than a capital loss. The applicable principle was that a fraud or embezzlement loss becomes allowable in the year it is discovered or crystallises, when recovery is no longer reasonably expected; the claim was therefore allowable in the relevant year and the disallowance was deleted. Because the penalty under section 271(1)(c) rested only on that deleted addition, the penalty also ceased to survive and was deleted. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773889