https://www.taxtmi.com/caselaws?id=49259 Where foreign currency originally received as revenue is later earmarked, with RBI approval, for acquiring capital goods for a manufacturing business, the later appropriation is treated as a separate capital transaction and not part of trading operations. The fact that the dollars remained abroad until repatriation does not change that character. Accordingly, any gain arising from exchange fluctuation on realisation is attributable to capital employed for capital purposes and is a capital accretion, not taxable business profit. The court affirmed the negative answer to the referred question and held the surplus outside trading income. en-us Thu, 13 Jan 1966 00:00:00 +0530 Sun, 17 Aug 2014 13:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49259 Where foreign currency originally received as revenue is later earmarked, with RBI approval, for acquiring capital goods for a manufacturing business, the later appropriation is treated as a separate capital transaction and not part of trading operations. The fact that the dollars remained abroad until repatriation does not change that character. Accordingly, any gain arising from exchange fluctuation on realisation is attributable to capital employed for capital purposes and is a capital accretion, not taxable business profit. The court affirmed the negative answer to the referred question and held the surplus outside trading income. Case-Laws Income Tax Thu, 13 Jan 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49259