Tribunal held that although there was import of capital assets in those years when external commercial loans were taken there was substantial exports also and the assertion of the assessee was that such export proceeds were used for import of capital assets and foreign exchange loan was not used for that purpose. There was no evidence on record to show that the foreign exchange loans were used for import of capital goods. The Commissioner (Appeals) was right in deleting the disallowance made by the Assessing Officer of foreign exchange loss.  (AY. 2011-12, 2012-13)