Accounting for Fixed Assets under Accounting Standard 11 and the Corresponding Ind AS (Ind AS 21/Ind AS 101)
Introduction
Accounting for fixed assets (property, plant and equipment—PPE) acquired, financed, or otherwise exposed to foreign currency risk is a recurring area of judgement in Indian practice. While AS 10 governs fixed assets under the Accounting Standards (AS) framework, the recognition and subsequent measurement of foreign exchange differences is dealt with by AS 11, “The Effects of Changes in Foreign Exchange Rates.” Under Ind AS, the comparable guidance is Ind AS 21 for foreign currency, read with Ind AS 16 for PPE, Ind AS 23 for borrowing costs, and transition relief in Ind AS 101. In addition, tax law (especially section 43A of the Income-tax Act, 1961) and regulatory provisions (e.g., RBI’s ECB framework) often shape corporate policy choices and disclosures.
This article provides a practitioner-focused analysis of how foreign exchange differences interact with the accounting for fixed assets. It explains the fundamental concepts embedded in AS 11 and Ind AS 21, contrasts legacy carve-outs (e.g., paragraphs 46/46A of AS 11 and the Foreign Currency Monetary Item Translation Difference Account—“FCMITDA”) with the Ind AS regime, and illustrates complexities through corporate case studies, numerical examples, and industry-specific scenarios. The discussion is intended for experienced chartered accountants who routinely advise on capital projects, cross-border acquisitions, and financing structures.
Objectives and Scope
The objectives are to: (a) identify when foreign exchange differences adjust the carrying amount of PPE; (b) distinguish between recognition in profit and loss versus capitalization; (c) coordinate the accounting with borrowing costs, hedge accounting, and tax; and (d) surface disclosure and control requirements. The scope includes:
- Purchase of PPE from foreign vendors;
- Foreign currency borrowings used to acquire or construct PPE;
- Capital work-in-progress (CWIP) and pre-operative phases;
- Decommissioning, restoration, and similar provisions denominated in foreign currency;
- Hedge designations for firm commitments and highly probable forecast transactions related to PPE;
- Transition to Ind AS and the continuing impact of past GAAP choices.
Conceptual Foundations: AS 11 and Ind AS 21
1) Foreign currency transactions and monetary items: A foreign currency transaction is recorded at the spot rate on the date of the transaction. Monetary items (receivables, payables, loans) are restated at each balance sheet date using the closing rate; exchange differences arise on restatement and settlement. Non-monetary items measured at historical cost are not retranslated; those measured at fair value are translated at the rate when the fair value was determined.
2) Functional currency: Ind AS 21 requires determination of functional currency (the currency of the primary economic environment). Most Indian companies have INR functional currency; however, specific subsidiaries or special purpose vehicles (SPVs) may have a non-INR functional currency, affecting translation of their PPE and exchange differences in separate versus consolidated financial statements.
3) Presentation currency and consolidation: For a foreign operation with non-INR functional currency, assets and liabilities (including PPE) are translated at closing rates; exchange differences go to other comprehensive income (OCI) as a foreign currency translation reserve (FCTR) until disposal. This is distinct from exchange differences on the monetary items of an INR-functional entity.
4) Prudence and faithful representation: AS 11 embeds accrual accounting and neutrality—losses and gains are recognized symmetrically unless specific guidance prescribes otherwise (e.g., AS 11 paras 46/46A allowed a deferral/capitalization option under Indian GAAP). Ind AS generally requires expensing of exchange differences in P&L except where capitalization is required by Ind AS 23 as part of borrowing costs or when the exchange difference forms part of the cost of a qualifying asset under specific conditions.
AS 11 under Indian GAAP (Legacy) — The Para 46/46A Regime
Historically, AS 11 distinguished between:
- Regular exchange differences on monetary items—recognized in P&L; and
- A special option (paras 46/46A introduced by MCA notifications) for long-term foreign currency monetary items (LTFMI). Entities could:
(a) Capitalize exchange differences to the cost of depreciable assets to the extent they related to acquisition of such assets; and
(b) In other cases, accumulate exchange differences in FCMITDA and amortize over the balance term of the item.
Key features and practice points under AS 11 (legacy):
- “Long-term” was generally interpreted with reference to the original/remaining term of the monetary item (e.g.,>12 months).
- Capitalization to PPE was limited to exchange differences directly related to the acquisition of depreciable assets (including CWIP).
- FCMITDA presented as a separate line item under Reserves&Surplus (or a separate head) and amortized over the residual term; unrealized exchange gains could be recognized to the extent of previously recognized losses or based on policy alignment.
- Depreciation on the increased carrying amount of PPE consequent on capitalization was charged prospectively.
- The option was irrevocable and required transparent policy disclosure.
Illustration 1 — Capitalization under AS 11 para 46/46A
A company contracts a USD 10 million turbine (CWIP) at USD/INR 70 on 1 April 20X1. Payment is via a 5-year USD loan drawn on the same date. On 31 March 20X2, USD/INR is 78. The loan is a long-term monetary item.
- Initial recognition: Equipment recorded at INR 700 million (USD 10m × 70).
- Year-end restatement: Loan restated to INR 780 million—exchange loss INR 80 million.
- Policy: Company opts under para 46/46A to capitalize exchange loss related to acquisition of depreciable assets.
Journal (31 March 20X2): Dr PPE/CWIP 80; Cr Foreign exchange fluctuation (or Loan) 80.
Result: Asset base increases to INR 780 million; future depreciation increases accordingly.
Borrowing Costs Intersection under AS 16 / Ind AS 23
Exchange differences on foreign currency borrowings may be treated as an adjustment to interest costs in two ways:
- AS 16 permits adjustment to interest cost of exchange differences to the extent they are regarded as an adjustment to interest cost on the borrowing;
- Ind AS 23 similarly permits capitalization of the portion of exchange differences considered to be an adjustment to interest costs for a qualifying asset, using a “difference between interest on functional currency borrowing and foreign currency borrowing” approach.
Illustration 2 — Exchange difference as adjustment to interest
Entity borrows USD 5 million at 3% to fund a qualifying plant under construction; an equivalent INR borrowing would cost 10%. During the year, exchange loss on the USD loan is INR 18 million; interest at 3% translated is INR 12 million. The incremental cost relative to the INR borrowing (at comparable principal) is capped at INR 8 million (i.e., 10% minus 3% on comparable base). Capitalize INR 8 million as borrowing cost; the balance INR 10 million exchange loss goes to P&L under Ind AS. Under AS 11 (para 46/46A), entities might have capitalized the entire loss to PPE if directly related to acquisition—hence a key GAAP difference.
Ind AS Regime — Ind AS 21, Ind AS 16, Ind AS 23 and Ind AS 101
Under Ind AS:
- Exchange differences on foreign currency monetary items are recognized in P&L when they arise (either on restatement or settlement), except:
– For foreign operations translation differences (OCI via FCTR);
– For amounts capitalized as borrowing costs under Ind AS 23 for qualifying assets; and
– For certain long-term provisions where the discount unwinding interacts with foreign currency risk (discussed below).
- Capitalization to PPE is not permitted merely because the item relates to acquisition of PPE. The specific para 46/46A option does not exist in Ind AS.
- Transition relief: Ind AS 101 allows an entity to continue its previous GAAP policy for exchange differences arising from long-term foreign currency monetary items recognized in PPE or FCMITDA for periods up to the transition date. The carrying amounts at transition can be retained, and amortization policies for any remaining FCMITDA may continue as per the previous policy. However, for post-transition periods, Ind AS rules apply.
Illustration 3 — Ind AS 101 transition
On transition date (1 April 20X1), an entity has INR 120 million of exchange differences capitalized in PPE under previous GAAP and INR 30 million balance in FCMITDA to be amortized over 3 years. Under Ind AS 101, the entity elects to continue the previous GAAP policy. The carrying amount of PPE includes the INR 120 million uplift. The INR 30 million FCMITDA continues to be amortized to P&L over 3 years. New exchange differences from 1 April 20X1 are recognized in P&L unless eligible for capitalization under Ind AS 23 as borrowing costs.
CWIP, Pre-Operative Phases, and Commencement of Depreciation
- Exchange differences incurred during construction: Under Ind AS, recognize in P&L, except to the extent qualifying as borrowing costs. Under AS 11 para 46/46A, entities often capitalized exchange losses directly into CWIP.
- Ready for intended use: Depreciation starts when the asset is available for use. Capitalization of borrowing costs ceases at this point; exchange differences thereafter normally go to P&L.
- Componentization: Under Ind AS 16, component accounting may cause different capitalization periods and borrowing cost allocations for different components of a complex asset (e.g., refinery units).
Corporate Case Study A — Power Generation SPV (Indian GAAP transitioning to Ind AS)
Facts: A power SPV imported boilers and turbines (USD 150m) funded by a 10-year USD ECB. Under AS 11 para 46/46A, the company capitalized exchange losses during 20X0–20X3 aggregating INR 2.4 billion into PPE. Depreciation increased by INR 120 million p.a. On Ind AS transition (1 April 20X4), the company elected Ind AS 101 relief to retain the carrying amount including the capitalized differences; a residual FCMITDA of INR 200 million was amortized over remaining 5 years.
Issues analyzed:
- Post-transition exchange differences recognized in P&L, causing volatility in earnings and DSCR covenants.
- • Management implemented a hedge program using USD-INR forwards for 70% of principal exposure aligned with debt amortization. Hedge accounting under Ind AS 109 designated the forwards as cash flow hedges; effective OCI recognized in equity, recycled to P&L on interest/principal cash flows, reducing volatility.
- • Auditor focus: Clear disclosures on (i) Ind AS 101 election; (ii) PPE carrying amounts including capitalized differences; (iii) hedge accounting policy and ineffectiveness.
Corporate Case Study B — Port Developer with USD Revenue
Facts: A port operator contracted USD-denominated cranes funded by a USD term loan. Revenue from foreign containers is also USD-linked. Functional currency remains INR.
Judgement: Because a significant portion of cash inflows is USD-linked, the entity argued that exchange losses on the USD loan are economically offset by USD revenue. Under Ind AS 21, however, exchange differences on the monetary item must be recognized in P&L unless hedge accounting is applied. The entity therefore designated the USD loan as a hedging instrument in a cash flow hedge of forecast USD revenue, documenting hedge relationships and effectiveness testing.
Impact: Effective portions of hedge gains/losses deferred in OCI, with reclassification to P&L aligning with revenue recognition. PPE accounting remained unaffected; no direct capitalization of exchange differences to the cranes’ cost was permitted under Ind AS (contrast with possible capitalization under AS 11 para 46/46A before transition).
Corporate Case Study C — Pharma Plant with EUR Equipment and INR Loan
Facts: A pharma entity purchased a EUR 25m production line with deferred payments in EUR to the vendor (a monetary payable) while raising an INR rupee term loan domestically.
Accounting: The vendor payable is restated at closing rate each period; exchange differences go to P&L. Because the borrowing is in INR, there is no foreign currency borrowing to evaluate under Ind AS 23. No capitalization of exchange differences is allowed. However, if an effective fair value hedge of the EUR payable is designated using EUR-INR forwards, changes in fair value of the payable attributable to the hedged risk would adjust the carrying amount with offsetting P&L effects from the derivative, stabilizing profit.
Learning: The currency of the borrowing is not decisive; what matters is whether the exchange difference meets the borrowing cost capitalization criteria or is otherwise eligible through hedge accounting impacts (which do not capitalize into PPE under Ind AS).
Industry-Specific Complexities
1) Oil & Gas and Mining: Large, long-lead equipment (rigs, compressors) is often sourced in USD. Under AS 11 legacy, many entities capitalized exchange losses to PPE. Under Ind AS, post-transition exchange differences hit P&L. For decommissioning provisions denominated in USD, both the unwinding of discount (finance cost) and period-end retranslation can create volatility. The remeasurement of the provision under Ind AS 37 adjusts the asset (PPE) when the provision changes, but the foreign exchange difference itself is recognized in P&L; however, if the change in the provision arises from discount rate updates, the corresponding asset adjustment applies.
2) Airlines and Shipping: Leases (Ind AS 116) often denominated in USD. Right-of-use (ROU) assets and lease liabilities are recognized; the lease liability is a monetary item retranslated each period if the functional currency is INR and lease is payable in USD. Exchange differences on the lease liability go to P&L; they are not capitalized to the ROU asset. This is a material change from legacy views where some attempted capitalization under AS 11 para 46/46A for finance leases.
3) Power and Infrastructure: EPC contracts include foreign currency variation clauses. Contract assets/liabilities and advances denominated in foreign currency are monetary and retranslated with exchange differences in P&L. When progress payments are hedged, OCI deferrals (cash flow hedges) may be used to match earnings but do not adjust PPE cost under Ind AS.
4) Real Estate Developers: CWIP for elevators, HVAC systems, and façade materials sourced in EUR/JPY must consider timing of risk transfer. If the contract is FOB shipping point, control may transfer earlier; however, the foreign currency payable remains monetary until settled. Ind AS 23 capitalization of borrowing costs ends when the respective component is ready for intended use, even if other components remain in CWIP.
5) IT/ITES Campus Builds: Entities with USD receivables from customers sometimes rely on “natural hedges.” Without formal hedge accounting, exchange gains on receivables cannot be netted against losses on USD payables or borrowings in accounting presentation; they are reported separately in finance costs/other income.
Numerical Illustrations and Journal Entries
Illustration 4 — Vendor Credit in USD (Ind AS)
- 1 July 20X1: Purchase equipment for USD 2m on 90-day credit. Spot 74.00. Record PPE INR 148.00m and trade payable INR 148.00m.
- 30 Sept 20X1: Closing rate 75.50. Restate payable to INR 151.00m; recognize exchange loss INR 3.00m in P&L. PPE remains at historical INR 148.00m.
- 1 Oct 20X1: Settle at rate 75.20. Pay INR 150.40m; recognize exchange gain of INR 0.60m from 75.50 to 75.20.
Journal (30 Sept): Dr Exchange loss 3.00; Cr Trade payable 3.00.
Journal (1 Oct): Dr Trade payable 151.00; Cr Bank 150.40; Cr Exchange gain 0.60.
Illustration 5 — ECB for Plant under Construction (Ind AS 23)
- INR functional entity borrows USD 20m at 4% to construct a qualifying asset; comparable INR borrowing rate is 11%. During the year: FX loss INR 120m; interest INR 66m (4% × 20m × avg INR rate). Cap the capitalization to the differential cost relative to INR borrowing: 7% of principal equivalent equals, say, INR 100m. Capitalize INR 100m as borrowing cost; recognize INR 20m exchange loss in P&L. Interest of INR 66m is capitalized as part of borrowing costs as well, subject to avoidable cost tests and suspension rules during extended interruptions.
- Upon readiness for intended use, cease capitalization prospectively.
Illustration 6 — Decommissioning Provision in USD (Ind AS 37/21)
- At initial recognition, present value of USD 3m decommissioning obligation discounted and translated to INR with corresponding increase to PPE.
- At year-end, retranslate the provision at closing rate; exchange difference goes to P&L. Separately, unwind the discount (finance cost). If there is a remeasurement due to revised estimates or discount rate changes, adjust the PPE carrying amount.
Illustration 7 — FCMITDA under AS 11 and Transition
- Under previous GAAP, entity recognized INR 250m in FCMITDA relating to non-asset long-term USD loans; amortization over 10 years at INR 25m per year. At Ind AS transition with 6 years remaining, continue amortization for 6 years through P&L. New exchange differences post-transition cannot be routed to FCMITDA.
Tax Interactions: Section 43A and MAT/Deferred Tax
- Section 43A adjusts the actual cost of assets acquired from outside India for changes in foreign exchange rates at the time of payment. For books, AS 11/Ind AS 21 require accrual-based recognition at reporting dates, not only on payment. This creates book–tax timing differences.
- MAT / Ind AS Schedule III: Under earlier MAT regimes, capitalization under para 46/46A affected book profits and MAT computation; careful tracking of reversals was necessary. Under current regimes, focus remains on reconciling P&L exchange differences, borrowing cost capitalization, and tax base adjustments for deferred tax under AS 22/Ind AS 12.
- Deferred Tax: Capitalization of exchange differences to PPE (where permitted) affects temporary differences through higher tax depreciation base versus accounting carrying amount or vice versa. Under Ind AS, immediate P&L recognition of exchange differences usually creates timing differences driven by section 43A adjustments upon payment; recognize deferred tax accordingly.
Hedge Accounting Considerations (Ind AS 109)
- Cash flow hedges of forecast purchases of PPE: Gains/losses on hedging instruments recognized in OCI and accumulated in the cash flow hedge reserve to the extent effective; when the hedged transaction results in a non-financial asset, Ind AS permits a “basis adjustment”—i.e., reclassify the accumulated OCI amount and include it in the initial carrying amount of the asset. This is a crucial path to adjust PPE cost under Ind AS without breaching the general prohibition on capitalizing exchange differences.
- Fair value hedges of firm commitments: Changes in fair value of the hedged item attributable to the hedged risk adjust the carrying amount of the firm commitment (a rarely recognized asset/liability) with offsetting P&L effects from the derivative; when the transaction occurs, the cumulative adjustment can be included in the initial carrying amount of the asset.
- Documentation and effectiveness: Robust hedge documentation at inception, designation of risk components (e.g., USD-INR spot), and prospective/retrospective effectiveness assessments are mandatory to achieve accounting outcomes.
Disclosure and Presentation
Key disclosures include:
Accounting policies for foreign currency translation, borrowing costs, hedge accounting, and Ind AS 101 elections;
- The amount of exchange differences recognized in P&L;
- For AS entities using para 46/46A (where still applicable in legacy periods), the amount capitalized to PPE and the FCMITDA movements;
- Borrowing cost capitalized and capitalization rates;
- Sensitivity to exchange rate movements for significant exposures;
- Reconciliation of OCI reserves (cash flow hedge reserve, FCTR).
Governance, Controls, and Audit Procedures
- Exposure identification: Maintain a register mapping foreign currency exposures to projects/assets, including vendor payables, foreign currency borrowings, lease liabilities, and decommissioning provisions.
- Policy elections: Document irrevocable elections (para 46/46A in legacy AS; Ind AS 101 transition choices) and hedge designations, including permissible ranges and risk appetite.
- Closing rate sources and cut-offs: Use reliable market sources for rates; ensure completeness of restatement entries at period end.
- CWIP gates and readiness assessments: Establish checklists for intended use, safety approvals, and performance tests to cease capitalization timely.
- Auditor focus areas: Consistency of policy application, impairment assessments when exchange losses materially uplift PPE carrying amounts, and adequacy of deferred tax accounting.
Frequently Encountered Pitfalls
- Treating all exchange differences as capitalizable merely because the underlying project is capital in nature—impermissible under Ind AS except via borrowing cost rules or hedge basis adjustments.
- Ignoring the currency of the monetary item: A foreign currency vendor payable can create exchange differences even if the borrowing is in INR; capitalization routes are limited.
- Failing to cease capitalization when an asset is ready for intended use, especially in phased commissioning environments.
- Misalignment between treasury hedging and accounting hedge relationships leading to P&L volatility despite economic hedges.
Overlooking section 43A payment-based adjustments and the resulting deferred tax.
Comprehensive Example — Integrated Refinery Project
Facts: An Indian refinery company undertakes a INR 50 billion expansion with significant USD-denominated equipment and a mix of USD ECBs and INR bonds. Project spans 30 months.
Year 1:
USD equipment commitments USD 400m at average contracted rate 74; USD loan drawn USD 250m at 3.5%; equivalent INR borrowing rate 10.5%.
Closing rate at year-end 79:
– Vendor payables USD 120m outstanding—exchange loss INR 600m to P&L.
– USD loan restatement loss INR 1,125m; interest at 3.5% equivalent INR 645m.
– Borrowing cost capitalization test: Cap exchange loss capitalization (as borrowing cost) at the interest differential: 7% on average principal; assume cap is INR 950m. Capitalize INR 950m of the exchange loss plus interest INR 645m (subject to CWIP eligible period). Recognize excess exchange loss INR 175m in P&L.
Year 2:
- Rate moves to 76 (INR appreciation):
– Vendor payables reduced generating exchange gain INR 360m to P&L.
– USD loan retranslation gain INR 750m; only interest differential (if any) capitalizable—now negative; hence no exchange capitalization. Gains go to P&L.
Commissioning:
- On mechanical completion, capitalization ceases; remaining exchange differences flow to P&L. Hedge reserves accumulated on forecast equipment purchases are basis-adjusted into PPE at the point of recognition of the related assets.
Outcomes:
- PPE carries cumulative borrowing costs including capped exchange losses and hedge basis adjustments; net P&L impact reflects non-capitalizable FX movements; disclosures explain the policy framework and sensitivity.
AS vs Ind AS — Side-by-Side Summary
- AS 11 (with paras 46/46A): Option to capitalize exchange differences on LTFMI to PPE; or defer in FCMITDA for non-asset items.
- Ind AS 21/23: No such option. Exchange differences recognized in P&L except (a) capitalization as part of borrowing costs for qualifying assets to the extent of interest differential, and (b) hedge basis adjustments under Ind AS 109 for non-financial items.
- Ind AS 101: Permits continuation of previous GAAP policy at transition for existing balances; no fresh capitalization under para 46/46A thereafter.
Real-Life Style Case Snapshots (Anonymized)
1) Telecom Tower Rollout: A telco capitalized large exchange losses to tower PPE under AS 11 para 46A during 2012–2014. On Ind AS adoption in 2016, the carrying amounts were retained; subsequent USD loan differences hit P&L. The company increased hedge coverage; quarterly volatility reduced, and analysts’ models stabilized.
2) Metro Rail Project: Mixed currency EPC—EUR rolling stock, JPY signaling. Prior to intended use, only the interest differential component of exchange losses was capitalized under Ind AS 23. On commissioning, FX moved favorably creating gains recognized in P&L; management communicated the non-cash nature to lenders to preserve covenant headroom.
3) Specialty Chemicals Plant: EUR vendor credit extended for 18 months. Because the payable is a monetary item, exchange differences hit P&L; however, a cash flow hedge using forwards allowed basis adjustment to the asset when the payable was settled and the plant recognized—improving EBITDA presentation thereafter.
Impairment Considerations
- Capitalization of exchange losses (where permissible) increases PPE carrying amount; entities must test for impairment indicators (AS 28 / Ind AS 36).
- Recoverable amount depends on value in use (sensitive to pricing, utilization) or fair value less costs of disposal. Currency devaluation that raises asset cost but not cash inflows can lead to impairment.
- Cash-generating unit (CGU) determination for large plants is critical; allocation of corporate assets and common borrowings impacts impairment calculations.
Checklists for Practitioners
Policy and Classification
- Determine functional currency for each entity.
- Identify all foreign currency monetary items linked to capital projects.
- Decide on Ind AS 101 elections and legacy AS 11 para 46/46A disclosures (if applicable historically).
Measurement and Capitalization
- Apply closing rate retranslation to monetary items.
- Under Ind AS, restrict capitalization of exchange differences to borrowing cost rules (interest differential) and hedge basis adjustments.
- Track CWIP gates; stop capitalization when ready for intended use.
Hedging and Documentation
- Align treasury hedges with accounting objectives; consider proxy hedges where direct hedges are impractical.
- Document hedge relationships, risk components, and effectiveness.
- Monitor hedge ineffectiveness and recycling.
Tax and Deferred Tax
- Map section 43A impacts on payment; reconcile with book entries.
- Compute deferred tax on temporary differences from capitalization and timing differences on FX.
- Track MAT/alternate regimes where relevant.
Disclosures and Controls
- Provide transparent footnotes on exchange differences, borrowing costs, hedge reserves, and Ind AS 101 choices.
- Establish rate source controls and cut-off reconciliations.
- Educate management and analysts on non-cash volatility items.
Conclusion
Under legacy AS 11, Indian entities enjoyed a policy option to capitalize exchange losses on long-term foreign currency monetary items directly to the cost of depreciable assets, or to defer them in FCMITDA for non-asset items. This approach softened P&L volatility but embedded currency movements into asset bases and depreciation, and raised analytical and tax complexities. The Ind AS framework, aligned with IFRS, eliminates this broad option. Exchange differences are generally recognized in profit or loss, with only two principal pathways to affect PPE: (i) capitalization as part of borrowing costs limited to the interest differential for qualifying assets under Ind AS 23; and (ii) basis adjustments arising from effective cash flow or fair value hedge relationships under Ind AS 109.
For practitioners, the discipline now lies in careful project scoping, tight alignment of treasury hedging with accounting mechanics, rigorous documentation, and robust disclosure. The interplay with section 43A, deferred tax, impairment testing, and covenant communication must be proactively managed. With these controls and frameworks, companies can faithfully represent the economics of currency risk around fixed assets while delivering comparability and transparency demanded by sophisticated stakeholders.


