Diminution in value of GoI Bonds allowable as revenue loss as investment made under commercial expediency

PCIT Vs Paradeep Phosphates Limited (Orissa High Court) Orissa High Court held that since the investment in Government of India Fertilizer Bonds [GoI Bonds] was made under commercial expediency it did not bring an asset of a capital nature and the diminution in the value of the said bond are allowable as revenue loss. Facts- The first issue is whether the Income Tax Appellate Tribunal erred in holding that the provisions of diminution of Government of India Fertilizer Bonds [GoI Bonds] is an allowable deduction. Another issue arose due to the disallowance of ₹ 2,84,34,453 by the AO which was...