Dy. CIT v. PTC India Financial Services Ltd. (2023) 104 ITR 1 (SN) (Delhi)(Trib)

S. 28(i) : Business loss-Foreign exchange rate fluctuation-Allowable as deduction.

Held that during the AYs 2017-18 and 2018-19, the assessee earned income on reinstatement of external commercial borrowings and duly offered it to tax and this was accepted by the Assessing Officer during the assessment proceedings. So, when the Department accepted the gains, the same treatment should be given to the loss. Hence, the addition was to be deleted.(AY.2012-13)