https://www.taxtmi.com/caselaws?id=346320 Where royalty and interest had already accrued in earlier years and were valued for treaty purposes at the relevant balance-sheet exchange rate, a later gain on remittance in foreign currency was held to arise only from currency fluctuation and the passage of time. Applying Accounting Standard 11 and the reasoning approved in Woodward Governor, the court treated that exchange difference as a separate receipt in the year of realisation rather than an accretion to the original income. The gain did not retain the character of royalty or interest for Indo-Malaysian treaty exemption and was taxable in India as distinct income. en-us Tue, 01 Aug 2017 00:00:00 +0530 Sat, 18 Nov 2017 14:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346320 Where royalty and interest had already accrued in earlier years and were valued for treaty purposes at the relevant balance-sheet exchange rate, a later gain on remittance in foreign currency was held to arise only from currency fluctuation and the passage of time. Applying Accounting Standard 11 and the reasoning approved in Woodward Governor, the court treated that exchange difference as a separate receipt in the year of realisation rather than an accretion to the original income. The gain did not retain the character of royalty or interest for Indo-Malaysian treaty exemption and was taxable in India as distinct income. Case-Laws Income Tax Tue, 01 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346320