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    <title>2023 (8) TMI 1731 - ITAT MUMBAI</title>
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    <description>Forward coriander-sale contract losses were disallowed as non-genuine business losses because related-party arrangements lacked advances, settlement payments, delivery, broker or exchange involvement, and a verifiable money trail, with entries ultimately adjusted through journals. Applying burden of proof, surrounding circumstances, preponderance of probabilities and human-probability principles, the arrangements failed to establish commercial reality and were treated as colourable tax-avoidance devices. The speculative-loss question did not require substantive determination once the underlying transactions were rejected as sham; observations on speculative character and set-off restrictions were not an independent basis for the disallowance.</description>
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