CIT v. K.P.D. Sigamani (2020) 120 taxmann.com 254 (Mad.)(HC) Editorial : SLP of revenue is dismissed, CIT v. K.P.D. Sigamani (2020) 120 taxmann.com 255/ 275 Taxman 4 (SC)

S. 70 : Set off of loss-One source against income from another source-Same head of income-Tax avoidance-Long term capital gains set off against short term capital loss- Forfeiture of call monies-Set off loss is held to be allowable. [S. 4, 45]

Dismissing the appeal of the revenue the Court held that forfeiture was not claimed to be bogus nor it had been shown to be a fraudulent manner or colorable devise. There is no allegation that the amount invested in forfeited shares had come back to the assessee in any form whatsoever. Loss is held to be allowable. (AY.2007-08)