“4.2 We heard the Ld DR and perused the material on record. It is now well settled proposition of law that the MTM losses arising on revaluation of revenue assets and the related forward contracts as at the end of the year is allowable as deduction as per the decisions referred to in the previous paragraph. We notice that the AO has disallowed the loss of Rs.5,22,43,701/-. However, the break-up details of losses are not given in the Assessment Order and hence we could not identify as to whether they are related to revenue items only. The Ld D.R also submitted that the loss arising from revenue assets and related forward contracts are allowable as deduction. Accordingly, we are of the view that this factual aspect needs to be verified. Accordingly, we restore this issue to the file of the AO to examine the claim of the assessee afresh following the decision rendered by the jurisdictional High Court in the case of M/s. Mphasis Ltd) (supra) and also the decision rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (supra). Needless to mention that, the losses arising on revaluation as at the yearend of revenue items and the forward contracts related to the revenue items should be allowed as deduction.
