High Court Upholds ITAT Ruling: Real Income Over Hypothetical in Plastic Division Loss Case.

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....In a case concerning disallowance of loss incurred in a plastic division, the assessee followed the mercantile system of accounting, and contracts were accounted for on an accrual basis. The Income Tax Appellate Tribunal (ITAT) dismissed the revenue appeal, holding that tax is levied on real income with aspects of certainty. The High Court upheld the ITAT's decision, considering the Supreme Court's ruling in Commissioner of Income Tax v. Excel Industries Ltd., which emphasized levying tax on real income rather than hypothetical income. The settlement agreement acknowledged the contract's partial disintegration, causing the assessee to lose the right to receive the full transaction value. Accounting Standards (AS) 4 and 9 were considered for contingencies occurring after the balance sheet date. The High Court found no manifest error in the ITAT's judgment favoring the assessee.....