Held that the assessee having borrowed funds for external commercial borrowing to acquire capital assets, in the restatement of the account to be made every year, there was bound to be a change in the value of the borrowings in view of fluctuation in the foreign exchange. The Tribunal had rightly held that the adjustment on account of foreign exchange rate fluctuation was required to be made to actual cost at the end of every year after the amendment of section 43A with effect from April 1, 2003 and had upheld the order of the Commissioner (Appeals) that the gains arising on account of foreign exchange fluctuation were not liable to tax as it was on the capital account. (AY.2010-11)