Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights November 2021 Year 2021 This

Revision u/s 263 by CIT-A - AO’s order is not erroneous and ...


Commissioner's Revision u/s 263 Overturned: Mark-to-Market Loss on Forward Contracts Allowed as Deduction.

November 20, 2021

Case Laws     Income Tax     AT

Revision u/s 263 by CIT-A - AO’s order is not erroneous and prejudicial to the interest of revenue since mark to market loss incurred by Company on revaluation of forward contracts is an allowable deduction as the loss claimed by the assessee co. was in accordance with a recognized method of accounting, the loss claimed by the assessee co. was not a notional/contingent loss, but is an actual loss and the mark-to-market loss on forward contracts has not been treated as a contingent liability in the audited financial statements. Thus, the mark-to-market loss on forward contracts cannot be said as contingent in nature. - Revision order u/s 263 set aside - AT

View Source

 


 

You may also like:

  1. Mark to market loss - Contingent loss or not - Unrealized foreign exchange forward contract losses - 'mark to market' loss on such future and forward contracts are not a...

  2. Allowing mark to market loss on account of outstanding forward contract liability - the forward contract transactions so entered during the course of regular business...

  3. The assessee, a Foreign Portfolio Investor registered in India, entered into Forward Foreign Exchange Contracts (FCC) with HDFC Bank to safeguard against foreign...

  4. When the contention of the assessee that all the forward contracts were settled by way of actual delivery through dollars received on export receivables, the assessee...

  5. Disallowance on account of 'mark to market loss' on F&O transaction - additions deleted - AT

  6. "Mark to Market” loss - AO did not disallow the claim of loss but CIT(A) disallowed the claim of loss - In the absence of any fact with regard to the nature of the said...

  7. Disallowance of swap contract loss - whether the loss is not real but a notional loss for the reason that there was no actual transaction carried out by the assessee -...

  8. Assessee's contention upheld that for AY 2019-20, profit is required to be set off against business loss of AY 2018-19 and remaining profit against brought forward...

  9. Nature of loss - Speculative loss or normal business loss - Marked to market loss on hedging of the transaction - The Appellate Tribunal held that speculative...

  10. Disallowance of foreign exchange loss on account of marking to mark to market of forward contracts - "expenditure" as used in section 37 in Income Tax Act may in the...

  11. Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was...

  12. Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the...

  13. Relief to start-ups in carrying forward and setting off of losses - Relaxation in 51% holding of shares for the purpose of carry forward of losses of eligible star-up...

  14. Revision u/s 263 by CIT - set off of the brought forward "non-speculative business loss" against the "profit of speculative business" - provisions of section 72 and 73,...

  15. Forward contract cancellation loss - In order to hedge against losses, the assessee had booked foreign exchange in the forward market with the bank. - allowed as business loss - HC

 

Quick Updates:Latest Updates