https://www.taxtmi.com/caselaws?id=161967 Mere appreciation in the Indian-rupee value of a foreign fund does not, by itself, create taxable income. Where the assessee's Pakistan balance was neither remitted to India nor actually converted into Indian currency, the exchange difference remained only a potential book adjustment until the fund was used. Utilisation of that fund to pay Pakistan income-tax was a non-business operation and did not amount to realisation in the course of a taxable transaction. Book entries alone were insufficient to establish a real taxable profit from exchange fluctuation, so the amount was not treated as income for the relevant assessment year. en-us Sat, 09 Sep 1961 00:00:00 +0530 Wed, 12 Feb 2014 15:17:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=161967 Mere appreciation in the Indian-rupee value of a foreign fund does not, by itself, create taxable income. Where the assessee's Pakistan balance was neither remitted to India nor actually converted into Indian currency, the exchange difference remained only a potential book adjustment until the fund was used. Utilisation of that fund to pay Pakistan income-tax was a non-business operation and did not amount to realisation in the course of a taxable transaction. Book entries alone were insufficient to establish a real taxable profit from exchange fluctuation, so the amount was not treated as income for the relevant assessment year. Case-Laws Income Tax Sat, 09 Sep 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=161967