Introducing the βIn Favour Ofβ filter in Case Laws.
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Introducing the βIn Favour Ofβ filter in Case Laws.
Try it now in Case Laws β


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TP Adjustment - When foreign exchange loss is to form part of the total base of the taxpayer for the purpose of charging a mark up to its AEs as it drives income from its overseas AEs and it being a cost plus entity, the taxpayer earns foreign exchange loss incurred if any, foreign exchange fluctuation is operating in nature in order to compute margins, hence ld. DRP/TPO/AO has erred in treating foreign exchange loss as non-operating item. - AT