TaxTMI 
TaxTMI 
1986 (1) TMI 51
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.... of law : " Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the loss of Rs. 8,96,300 suffered by the assessee in speculation transactions in PDOs was to be set off against its brokerage income earned from those transactions?" The grievance of the Department is that the Tribunal has allowed the speculation loss of Rs. 8,96,300 to be deducted f....
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....It was never the practice of the assessee to describe the profit and loss of PDO transactions as a separate business in speculation. The case of the Income-tax Officer is that the brokerage income should be treated as business income and the PDO loss should be regarded as speculative loss. The Appellate Assistant Commissioner held that these transactions were interlinked and could not be regarded ....
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....ransactions as inseparable from the business dealings in PDOs in such transactions. The Tribunal upheld the assessee's contention that earning of brokerage or loss or profit from PDO transactions were to be treated as inseparable. The decision of the Tribunal appears to us to be correct. The assessee was dealing in PDOs. The brokerage that it earned from dealing in PDOs was shown as profit. ....