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        Case ID :
        Income Tax

        ITAT ruled on several transfer pricing adjustments in the...

        Transfer Pricing Adjustments: Comparable Selection Criteria and Foreign Exchange Gains Treated as Operating Income

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee's ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.
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