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ITAT ruled on transfer pricing comparables and foreign exchange gains, directing: (1) Net gain from foreign currency transactions of Rs. 17.02 crore to be treated as operating income; (2) Excluding four comparables (Manipal Digital Systems, CES, MPS, Domex E-Data) as functionally different; (3) Retaining Tech Mahindra Business Services as a valid comparable; (4) Excluding Integra Software Services, Vitae International Accounting, and Access Healthcare Services based on precedent; (5) Rejecting Global Healthcare Billing and Digicall Global as inappropriate comparables; (6) Including R Systems International as a comparable; and (7) Excluding Bhilwara Info Technology, Cosmic Global, and Jindal Intellicom from the comparable list for calculating Profit Level Indicator under Transactional Net Margin Method.
ITAT ruled on transfer pricing comparables and foreign exchange gains, directing: (1) Net gain from foreign currency transactions of Rs. 17.02 crore to be treated as operating income; (2) Excluding four comparables (Manipal Digital Systems, CES, MPS, Domex E-Data) as functionally different; (3) Retaining Tech Mahindra Business Services as a valid comparable; (4) Excluding Integra Software Services, Vitae International Accounting, and Access Healthcare Services based on precedent; (5) Rejecting Global Healthcare Billing and Digicall Global as inappropriate comparables; (6) Including R Systems International as a comparable; and (7) Excluding Bhilwara Info Technology, Cosmic Global, and Jindal Intellicom from the comparable list for calculating Profit Level Indicator under Transactional Net Margin Method.
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