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    <description>Foreign exchange fluctuation loss on closing balances in EEFC accounts was treated as a real revenue loss, not a notional or capital loss, because the balances represented export proceeds used in the ordinary course of business and retained the character of circulating capital. Restatement at year-end exchange rates, when consistently recognised under the regular method of accounting, was accepted as reflecting a monetary trading item. Applying the settled principle that exchange gains or losses on trading assets or circulating capital are revenue in nature, the loss was allowable as a business deduction under section 37(1) and the disallowance was deleted.</description>
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