Section 37(1), 40(a)(ia) and 43(5) of the Income Tax Act, 1961 — Business Expenditure — Provisions of section 43(5) not attracted as assessee having been entered into hedging contracts with two banks to secure itself against fluctuation in foreign currency rate vis-a-vis foreign currency loan whereby the banks undertook to pay interest on the loan amount to the lender in lieu of payment of fixed amounts, there was no purchase or sale of any commodity which was settled otherwise than by actual delivery — SC Johnson Products P. Ltd. vs. Deputy Commissioner of Income tax [2018] 196 TTJ (Delhi) 410