Foreign Currency Loan Losses Not Deductible: Section 37(1) Requires Assessee to Rebut Capital Field Presumption.

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....The presumption shall arise that loan is on capital field until the same is rebutted by the assessee company and hence the said notional loss arising on restatement/revaluation of foreign currency loans due to adverse foreign exchange fluctuations cannot be allowed as deduction u/s 37(1) - AT....