Gujarat HC Upholds Export-Linked Business Losses and Foreign Commission Payments

The High Court declined to admit Revenue appeals against the Tribunal's deletion of several disallowances involving an exporter. It upheld the concurrent factual findings that contract cancellation charges were directly connected with the export business, commission paid to non-resident agents for services rendered abroad was not taxable in India, and forward contracts linked to export receivables were hedging transactions rather than speculative transactions. The Court also sustained the deletion of a Section 14A disallowance in the absence of the requisite satisfaction by the Assessing Officer.