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    <title>Notional forex gain on Euro-loan conversion to subsidiary held capital, not taxable; USFDA costs allowed under s.37(1); s.148A(b) notice inapplicable</title>
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    <description>ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer&#039;s addition under ICDS VI was deleted and the CIT(A)&#039;s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO&#039;s reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue&#039;s appeal dismissed.</description>
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    <pubDate>Tue, 14 Oct 2025 09:39:31 +0530</pubDate>
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      <title>Notional forex gain on Euro-loan conversion to subsidiary held capital, not taxable; USFDA costs allowed under s.37(1); s.148A(b) notice inapplicable</title>
      <link>https://www.taxtmi.com/highlights?id=93320</link>
      <description>ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer&#039;s addition under ICDS VI was deleted and the CIT(A)&#039;s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO&#039;s reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue&#039;s appeal dismissed.</description>
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      <pubDate>Tue, 14 Oct 2025 09:39:31 +0530</pubDate>
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