Corporate TaxArticle·24 December 2025
Statutory Boundaries of Hedging losses
By JustIDT
Executive Summary
The Delhi ITAT’s ruling in PCL Foods Pvt. Ltd. draws a hard statutory line.
The commercial intent to manage forex risk does not override section 43(5).
For exporters and CFOs, this is a reminder that treasury strategy must be tax-aligned from day one, because in derivative taxation, form still trumps substance.
J the App by JustIDT takes a deep dive.
Foreign Exchange Hedging Losses under Income Tax Law; Analysis of ITAT Delhi in PCL Foods Pvt. Ltd.
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