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Gross MTM Loss Disallowance: Allowable Liabilities for Forward Foreign Exchange Contracts with Determinable Obligations at Balance Sheet Date.

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....Disallowance of gross MTM loss - the obligation accrued against the taxpayer the minute it entered into forward foreign exchange contracts. So, the forward foreign exchange contracts debited to the profit & loss account are allowable one being the liability having been crystallized when a pending obligation on the date of balance sheet is determinable with reasonable certainty.....

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