Section 92C of the Income-tax Act, 1961—Transfer pricing— Exchange loss need to be adjusted to the cost of fixed assets/cost of capital work in progress, hence, assessee is entitled for depreciation on such capital portion of the exchange fluctuation loss - Foreign currency loans utilised for acquiring fixed assets and overseas investments is to be capitalised and correspondingly depreciation need to be granted to the assessee, in this, the exchange loss pertaining to the period till the asset was put to use should alone be capitalised and thereafter, the same should be allowed as revenue expenditure - SATYAM COMPUTER SERVICES LTD. V/s DEPUTY CIT - [2020] 26 ITCD Online 142 (ITAT-MUMBAI)