Foreign exchange fluctuation loss on year-end restatement of an external commercial borrowing used to acquire capital assets remains in the capital field. The notes state that, although the borrowing from the parent company was subsequently converted into equity shares, the loss retained its capital character because the borrowing was obtained for capital assets. Following earlier Tribunal orders in the same taxpayer's case, the loss could not be claimed as business expenditure under the Act. The disallowance was sustained and the appeal was dismissed.
Foreign exchange fluctuation loss on year-end restatement of an external commercial borrowing used to acquire capital assets remains in the capital field. The notes state that, although the borrowing from the parent company was subsequently converted into equity shares, the loss retained its capital character because the borrowing was obtained for capital assets. Following earlier Tribunal orders in the same taxpayer's case, the loss could not be claimed as business expenditure under the Act. The disallowance was sustained and the appeal was dismissed.
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