Baby Memorial Hospital Ltd. v. ACIT (2019) 184 DTR 361/ 202 TTJ 913 / (2020) 77 ITR 484 (SN) (Cochin.) (Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue– Limited scrutiny–AO is bound to make prima facie enquiry– Revision is held to be valid–Capital or revenue-On merit foreign exchange loss for acquiring capital asset is held to be allowable as revenue expenditure. [S. 43(1), 143(1)]

Tribunal held that even in a case of limited scrutiny assessment, the AO is duty bound to make a prima facie enquiry as to whether there is any other item which requires examination.  Revision is held to be valid.  As regards foreign exchange fluctuation loss   is concerned  there was no potential escapement of income on the issue relating to allowability of foreign exchange loan taken for the construction of new building and additional equipment hence allowable as revenue expenditure.(AY.2014-15)