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2018 (3) TMI 1638 - AT - Income TaxAddition u/s 14A - Held that:- We are in agreement with contention of learned AR that disallowance of interest under Rule 8D 2(ii) should be with reference to the interest attributable to the investment and not to the entire interest, accordingly, we confirm the action of CIT(A) for directing the AO to recompute the interest. Disallowance by taking interest of ₹ 57, 57, 409/- in place of ₹ 8, 58, 89, 421/-. We direct accordingly. Treating loss incurred in share trading activity as ‘speculation loss’ or ‘business loss’ - Held that:- As decided in assessee's own case [2017 (5) TMI 972 - ITAT MUMBAI] Forward contracts entered into with the banks for hedging the losses due to foreign exchange fluctuations on the export proceeds are to be considered integral or incidental to the export activity of the assessee. It was further held that there is no requirement of law that there should be 1:1 correlation between the Forward Contracts and Export invoices and so long as the total value of forward contracts does not exceed, the claim of the assessee is sustainable as business loss. Accordingly, it was held that the forward contracts entered by the assessee, an exporter and not the dealer in foreign exchange, with the Banks as incidental to the export business, are business transactions and loss or gains is not of speculation nature. It was further specifically held that the loss arising on cancellation of matured forward contracts was allowable as deduction - Decided in favour of assessee
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