https://www.taxtmi.com/caselaws?id=49259 The Supreme Court upheld the High Court's decision that the surplus arising from the devaluation in the process of converting dollars into rupees for repatriation was an accretion to the fixed capital of the company and not subject to tax. Regarding the commission earned, the Court determined that when appropriated for purchasing capital goods with the Reserve Bank's permission, it retained its fixed capital character until repatriated to India, making it non-taxable. The Court emphasized the importance of the transaction's nature in determining tax treatment, concluding that any profit from such transactions is a capital profit and not taxable. 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 The Supreme Court upheld the High Court's decision that the surplus arising from the devaluation in the process of converting dollars into rupees for repatriation was an accretion to the fixed capital of the company and not subject to tax. Regarding the commission earned, the Court determined that when appropriated for purchasing capital goods with the Reserve Bank's permission, it retained its fixed capital character until repatriated to India, making it non-taxable. The Court emphasized the importance of the transaction's nature in determining tax treatment, concluding that any profit from such transactions is a capital profit and not taxable. Case-Laws Income Tax Thu, 13 Jan 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49259