Held  that the Assessing Officer had made disallowance of the exchange fluctuation under section 37 only for the reason that external commercial borrowing loans were utilised for the purpose of acquiring capital asset, which has enduring benefit. However, the Commissioner (Appeals) had made the disallowance by relying on section 43A. On appeal the Tribunal held that the disallowances under section 37 and under section 43A operate in different spheres. Section 43A is a deeming provision for adding or deducting the fluctuation loss or profit from the cost of the asset whereas disallowance under section 37 is for the reason that capital expenditure was specifically disallowed. There was merely reinstatement of losses per Accounting Standards without actual payment or remittance so as to invoke section 43A. Except for the assessment year in question, the reinstatement of income or loss from fluctuation of currency had been accepted in terms of the accounting done by the assessee. Therefore, the additional grounds were to be admitted. Addition is deleted. (AY.2014-15)