https://www.taxtmi.com/caselaws?id=470784 Claimed loss from forward contracts for coriander was rejected as non-genuine because the transactions lacked payment, delivery, broker or exchange involvement, independent verification, and commercial explanation, and were settled only through journal entries. Applying the burden of proof, substance-over-form approach and test of human probabilities, the loss was treated as arising from sham arrangements designed to create a tax set-off against share-trading profits. The asserted commodity-contract loss was also speculative and could not be set off against non-speculative business income. The disallowance of the loss and denial of its adjustment against share-trading income remained effective. en-us Fri, 31 Mar 2023 00:00:00 +0530 Sat, 08 Aug 2026 11:44:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470784 Claimed loss from forward contracts for coriander was rejected as non-genuine because the transactions lacked payment, delivery, broker or exchange involvement, independent verification, and commercial explanation, and were settled only through journal entries. Applying the burden of proof, substance-over-form approach and test of human probabilities, the loss was treated as arising from sham arrangements designed to create a tax set-off against share-trading profits. The asserted commodity-contract loss was also speculative and could not be set off against non-speculative business income. The disallowance of the loss and denial of its adjustment against share-trading income remained effective. Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470784