https://www.taxtmi.com/caselaws?id=168758 An exchange gain on converting Chinese dollar balances into sterling, and on later repurchasing Chinese dollars to repay agents' deposits, was treated as a capital accretion rather than trading income. The deposits were held to be in substance loans or capital receipts, repayable in Chinese dollars on termination of the agency and intended as security for the agents' obligations. As the company's business was marketing petroleum products and not dealing in foreign currency, and the deposits were not shown to have been used as circulating capital, the gain did not arise as a revenue receipt assessable under Case I of Schedule D. The company's position was upheld. en-us Mon, 07 May 1951 00:00:00 +0530 Wed, 25 Mar 2015 15:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168758 An exchange gain on converting Chinese dollar balances into sterling, and on later repurchasing Chinese dollars to repay agents' deposits, was treated as a capital accretion rather than trading income. The deposits were held to be in substance loans or capital receipts, repayable in Chinese dollars on termination of the agency and intended as security for the agents' obligations. As the company's business was marketing petroleum products and not dealing in foreign currency, and the deposits were not shown to have been used as circulating capital, the gain did not arise as a revenue receipt assessable under Case I of Schedule D. The company's position was upheld. Case-Laws Income Tax Mon, 07 May 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168758