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    <title>2026 (7) TMI 1814 - ITAT CHENNAI</title>
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    <description>Foreign exchange fluctuation loss arising on year-end restatement of an external commercial borrowing used to acquire capital assets retains a capital character. Conversion of the borrowing into equity shares does not alter the stated treatment of the loss. As the borrowing from the parent company was in the capital field, the restatement loss was treated as capital loss rather than a business-revenue expense. The notes also state that materially identical treatment had applied in the assessee&#039;s earlier assessment years, with no distinguishing facts or legal change identified. The loss is therefore not allowable as a revenue deduction.</description>
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      <description>Foreign exchange fluctuation loss arising on year-end restatement of an external commercial borrowing used to acquire capital assets retains a capital character. Conversion of the borrowing into equity shares does not alter the stated treatment of the loss. As the borrowing from the parent company was in the capital field, the restatement loss was treated as capital loss rather than a business-revenue expense. The notes also state that materially identical treatment had applied in the assessee&#039;s earlier assessment years, with no distinguishing facts or legal change identified. The loss is therefore not allowable as a revenue deduction.</description>
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