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DELHI HIGH COURT
VIBHU BAKHRU, PURUSHAINDRA KUMAR KAURAV
Principal Commissioner of Income Tax, Delhi-2 – Appellant
Versus
Simon India Ltd. – Respondent


Table of Content
1. revenue appeal against tribunal's order (Para 1 , 2)
2. questions raised for court's consideration (Para 3 , 4)
3. loss on forward contracts issue (Para 5 , 6)
4. ao's rationale for disallowance (Para 7 , 8 , 9)
5. assessee's claims on dividend income (Para 10 , 11 , 12)
6. cit(a) finds ao in error (Para 14 , 15)
7. tribunal's agreement with cit(a) (Para 18 , 19 , 20 , 21)
8. court's view on notional losses (Para 22 , 23)
9. forward contracts allowance reasoning (Para 25 , 26)
10. no substantial question of law arises (Para 32 , 40)

JUDGMENT

Vibhu Bakhru, J.

1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter `the Act') impugning an order dated 30.05.2017 (hereafter `the impugned order') passed by the Income Tax Appellate Tribunal, Delhi (hereafter `the Tribunal') in an appeal preferred by the Revenue (being ITA No.976/Del/2013) against the order dated 05.11.2012 (hereafter `the appellate order') passed by the learned Commissioner of Income Tax (Appeals) [hereafter `CIT(A)'

2. The Assessee had also preferred an appeal before the learned Tribunal against the appellate order being ITA 555/Del/2013, which was partly allowe

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