https://www.taxtmi.com/caselaws?id=311319 HC upheld ITAT's decision that foreign exchange gains arising from restatement of external commercial borrowings used for acquisition of capital assets are on capital account and not liable to tax. Relying on SC precedent and amended Section 43A, the court affirmed that such exchange fluctuations adjust the actual cost of the asset and do not constitute taxable income. On MAT under Section 115JB, HC held that, as per Explanation 1, clause 2(iii), the lower of brought forward book loss or unabsorbed depreciation must be allowed to be set off, accepting cumulative figures per CBDT Circular No.495. Questions of law were answered in favour of the assessee, with computation remitted to AO. en-us Mon, 19 Sep 2022 00:00:00 +0530 Wed, 26 Nov 2025 17:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311319 HC upheld ITAT's decision that foreign exchange gains arising from restatement of external commercial borrowings used for acquisition of capital assets are on capital account and not liable to tax. Relying on SC precedent and amended Section 43A, the court affirmed that such exchange fluctuations adjust the actual cost of the asset and do not constitute taxable income. On MAT under Section 115JB, HC held that, as per Explanation 1, clause 2(iii), the lower of brought forward book loss or unabsorbed depreciation must be allowed to be set off, accepting cumulative figures per CBDT Circular No.495. Questions of law were answered in favour of the assessee, with computation remitted to AO. Case-Laws Income Tax Mon, 19 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311319