Dismissing the appeal of revenue the Court held that loss arising out of foreign exchange fluctuation on forward contract being incurred by assessee in ordinary course of its business would not be considered as speculative in nature . Followed CIT v. D.Chetan & Co ( 2017 ) 390 ITR 36 ( Bom ) (HC) ( AY. 2009 -10 )
PCIT v. Mphasis Ltd. (2021) 281 Taxman 206 (Karn.) (HC)
S. 43(5) : Speculative transaction – Foreign exchange fluctuation – Forward contract- Not speculative in nature – Allowable as revenue expenditure [ S.37 (1) ]