Section 43A Applies Only to Foreign Currency Fluctuations During Loan Repayment, Not Year-End Loan Restatements.

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....Revision u/s 263 - the Ld Pr. CIT has correctly explained that the provisions of sec. 43A shall apply only to those fluctuations in foreign currency which arises at the time of making repayment of loan, i.e., it does not apply to marked to market loss arising on account of restatement of loan at the year end.....