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Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
