https://www.taxtmi.com/caselaws?id=470784 Commercial substance and human probabilities are central to assessing claimed business losses from forward commodity contracts. Where contracts lack payment, delivery, broker or exchange involvement, independent verification, and are settled only through journal entries, the burden of proof may not be discharged. The notes identify substance over form and surrounding circumstances as grounds for treating purported coriander forward contracts as sham arrangements designed to generate a tax set-off. They also state that a non-genuine commodity-contract loss, characterised as speculative, cannot be adjusted against non-speculative share-trading business income. 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 Commercial substance and human probabilities are central to assessing claimed business losses from forward commodity contracts. Where contracts lack payment, delivery, broker or exchange involvement, independent verification, and are settled only through journal entries, the burden of proof may not be discharged. The notes identify substance over form and surrounding circumstances as grounds for treating purported coriander forward contracts as sham arrangements designed to generate a tax set-off. They also state that a non-genuine commodity-contract loss, characterised as speculative, cannot be adjusted against non-speculative share-trading business income. Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470784