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TMI Blog2019 (7) TMI 669X X X X Extracts X X X X X X X X Extracts X X X X ..... contracts which it claimed were not forward contracts by virtue of proviso clauses (a) (b) to Section 43 (5) of the Act - HELD THAT:- The contention was declined on the ground that no correlation between the forward contract transactions of gold and corresponding purchases and export of jewellery was established to satisfy the requirements of law. This Court is of the opinion that the assessee s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsel. O R D E R 1. Issue notice. Mr. Deepak Anand, Junior Standing Counsel accepts notice. 2. By consent of the parties, the petition is heard finally. 3. The assessee's writ petition is directed against the common order declining its application for rectification under Section 254(2) of the Income Tax Act; its appeal ITA No.430/2019 is also directed against the final order of the ITAT dated 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g the proceedings, which contained specific contracts and the transactions which the Revenue alleged were speculative. 5. In these circumstances, given that the Revenue's appeal has been remitted, the ITAT's approach in our opinion was not correct. Accordingly, the assessee's question with respect to the verification of the transactions and the correlation with specific contracts shall be examine ..... X X X X Extracts X X X X X X X X Extracts X X X X
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