Assessee earned a mark-to-market gain on loans given to an overseas party due to foreign exchange fluctuation on year-end reinstatement, which the Assessing Officer treated as taxable income. CIT (A) affirmed the addition. On appeal, the Tribunal held that since loans were not on revenue account and foreign exchange fluctuation gain, in instant case, was only due to reinstatement of accounts at end of year by considering year-end rate of exchange, no question arises for considering said gain as income of assessee for year under consideration and accordingly, addition was to be deleted. (AY. 2017-18)