TMI Blog1986 (1) TMI 51X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 from the profits earned from brokerage income. The Department contends that the PDO los ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctions 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 as separate and were of the same category. The Appellate Assistant Commissioner pointed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e 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. The PDO loss that was incurred was found by the Tribunal to be inseparable. In fact, the I ..... X X X X Extracts X X X X X X X X Extracts X X X X
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