Held that the unrealised foreign exchange gain was to be treated as capital receipt to be adjusted against cost of asset as and when realised in terms of section 43A of the Act. Followed Apollo Tyres Ltd. v. ACIT(2021) 438 ITR 536 (Ker)(HC). (AY.2011-12)
PCIT v. Apollo Tyres Ltd. (No. 3) (2022) 447 ITR 431 (Ker.)(HC)
S. 43A : Rate of exchange-Foreign currency-Foreign exchange fluctuation gain-Capital receipt-On actual realization to be adjusted against cost of asset.