https://www.taxtmi.com/caselaws?id=362814 Foreign exchange fluctuation loss on head office funds used for day-to-day project execution and working capital was treated as revenue expenditure because the amounts remained liabilities, were repaid in the same foreign currency, and no capital asset was created. The year-end loss arose only from retranslation due to rupee depreciation, and the same treatment had been accepted in earlier years on identical facts. Article 7(3) of the India-Spain DTAA did not bar a notional disallowance of this nature, so the deduction was allowable and the disallowance failed. en-us Thu, 28 Jun 2018 00:00:00 +0530 Wed, 08 Aug 2018 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362814 Foreign exchange fluctuation loss on head office funds used for day-to-day project execution and working capital was treated as revenue expenditure because the amounts remained liabilities, were repaid in the same foreign currency, and no capital asset was created. The year-end loss arose only from retranslation due to rupee depreciation, and the same treatment had been accepted in earlier years on identical facts. Article 7(3) of the India-Spain DTAA did not bar a notional disallowance of this nature, so the deduction was allowable and the disallowance failed. Case-Laws Income Tax Thu, 28 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362814