https://www.taxtmi.com/caselaws?id=437222 ECB funds raised for a new manufacturing project were treated as capital in nature where the loan proceeds were used for acquisition of capital assets, so the year-end foreign exchange restatement of the outstanding liability was not taxable as a revenue addition. Interest earned on fixed deposits from temporarily unutilised project funds was also treated as part of the project cost because it was inextricably linked to the borrowing and deployment of capital funds. The appellate forum further noted that a pure legal ground may be raised for the first time in appeal if the relevant facts are already on record, and the claim could be remitted for fresh adjudication. The Revenue's challenge failed on the substantive additions. en-us Thu, 27 Apr 2023 00:00:00 +0530 Sun, 30 Apr 2023 13:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437222 ECB funds raised for a new manufacturing project were treated as capital in nature where the loan proceeds were used for acquisition of capital assets, so the year-end foreign exchange restatement of the outstanding liability was not taxable as a revenue addition. Interest earned on fixed deposits from temporarily unutilised project funds was also treated as part of the project cost because it was inextricably linked to the borrowing and deployment of capital funds. The appellate forum further noted that a pure legal ground may be raised for the first time in appeal if the relevant facts are already on record, and the claim could be remitted for fresh adjudication. The Revenue's challenge failed on the substantive additions. Case-Laws Income Tax Thu, 27 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437222