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    <title>2025 (2) TMI 1932 - ITAT MUMBAI</title>
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    <description>Commodity loss on coriander contract settlement was disallowed because the assessee failed to prove genuine commercial substance, actual delivery, or credible evidence of a real business arrangement. The transaction was examined in light of surrounding circumstances, journal entries, close party relationship, and the test of human and preponderance of probabilities, and was found collusive. The dealings were also treated as speculative because they were settled otherwise than by actual delivery, outside a recognised commodity exchange, and did not satisfy the statutory exceptions or establish hedging linked to delivery contracts. As a result, the loss could not be allowed or set off against non-speculative business income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468875</link>
      <description>Commodity loss on coriander contract settlement was disallowed because the assessee failed to prove genuine commercial substance, actual delivery, or credible evidence of a real business arrangement. The transaction was examined in light of surrounding circumstances, journal entries, close party relationship, and the test of human and preponderance of probabilities, and was found collusive. The dealings were also treated as speculative because they were settled otherwise than by actual delivery, outside a recognised commodity exchange, and did not satisfy the statutory exceptions or establish hedging linked to delivery contracts. As a result, the loss could not be allowed or set off against non-speculative business income.</description>
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