IT-479R, "Transactions in Securities", para. 28-32

Where the writer of a put or call option treats gains or losses on income account, the premiums received will not be income until the option is exercised or expires.

Discussion of timing of recognition of gains and losses on exchange traded call and put options.

Para. 25: Gains or losses of a writer of naked options normally on inomce account, but CR will accept consistent reporting on capital account.

Para. 29: Premiums from writing call options on income account not recognized until exercise or expiry. (similarly re put options: para. 32).