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In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
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