proceedings, assessee made
written submissions and mentioned that the impugned forward contracts (FCs) are
linked or incidental to the export invoices of the year ... constitutes business loss'. Referring to the rest of the loss-yielded FCs, which are
cancelled prior to the due date, assessee mentioned that they
there is decision of the Tribunal where it is held that
the FCs are not commodities, considering the judgment of
Hon‗ble High court ... business‗, and thus, considering the nature of these
transactions, the impugned FCs cannot be deemed as the
speculation business without going into the "nature
verification of submissions,
the AO held that the assessee has entered into FCs with the financial
institutions and where closed without actual delivery of goods ... conclusion that the assessee is in the business of entering
into FCs and the same cannot be said to be hedging transaction. In the
instant
proceedings, assessee made
written submissions and mentioned that the impugned forward contracts (FCs) are
linked or incidental to the export invoices of the year ... constitutes ‗business loss'. Referring to the rest of the loss-yielded
FCs, which are cancelled prior to the due date, assesse mentioned that they
there is decision of the Tribunal
where it is held that the FCs are not commodities, considering the
judgment of Hon‗ble High court ... business‗, and thus, considering the nature of these
transactions, the impugned FCs cannot be deemed as the
speculation business without going into the "nature
which is as under:-
"2. TERMS AND CONDITIONS OF ENGAGEMENT
2.1 FCS hereby retains FCITES to provide Services in
the manner set forth below ... Customers - FCITES will provide Services in India
to FCS Customers as requested by FCS
b) Debtor Records - Debtor Records or access there
to shall
Fcs Manufacturing (India) Private ... vs Acit, Central Circle 2(1), Mumbai on 9 January, 2026
IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH ... Arising out of ITA No.6918/Mum/2024)
(Assessment Year: 2021-22)
FCS Manufacturing (India) Pvt. Ltd. ACIT-Central Circle 2(1)
Building C, Block
assessee is that the items at (1) and (8) namely, FCS
Software Solutions Ltd. and Compucom Software Ltd. (seg) have been wrongly included ... para 6.3.2. of his order, the TPO has
noticed in relation to FCS Software ltd that the said company had sales revenues from related
parties
Mondelez India Foods P. Ltd, Mumbai vs Dcit Rg 5(1)(2), Mumbai on 31
Cadbury India Ltd, Mumbai vs Addl Cit Rg 5(1), Mumbai on 17 February, 2021
