https://www.taxtmi.com/caselaws?id=466301 Foreign currency fluctuation loss on a loan used to acquire capital assets was treated as governed by section 43A, so the claimed revenue deduction was disallowed. Interest on borrowed funds was not disallowed under section 36(1)(iii) because the assessee had sufficient interest-free own funds, creating a presumption that advances to subsidiary concerns came from those funds. Disallowance under section 14A was not sustained because no exempt income was shown. Tax sparing credit under Article 25 of the India-Cyprus DTAA was upheld, as the treaty language was read in its ordinary sense and no separate proof of the Cypriot exemption's economic-development purpose was required. en-us Fri, 12 Apr 2019 00:00:00 +0530 Thu, 29 Jan 2026 11:42:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466301 Foreign currency fluctuation loss on a loan used to acquire capital assets was treated as governed by section 43A, so the claimed revenue deduction was disallowed. Interest on borrowed funds was not disallowed under section 36(1)(iii) because the assessee had sufficient interest-free own funds, creating a presumption that advances to subsidiary concerns came from those funds. Disallowance under section 14A was not sustained because no exempt income was shown. Tax sparing credit under Article 25 of the India-Cyprus DTAA was upheld, as the treaty language was read in its ordinary sense and no separate proof of the Cypriot exemption's economic-development purpose was required. Case-Laws Income Tax Fri, 12 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466301