https://www.taxtmi.com/caselaws?id=245173 ITAT Hyderabad upheld the DRP's view that extraordinary events like mergers impact profitability and require verification by the TPO, excluding such comparables if confirmed. Companies showing supernormal profits or questionable reputation were rightly excluded as comparables. The TPO's exclusion of companies with turnover vastly different from the assessee's was also upheld. The matter was remitted to the TPO for fresh ALP examination. Regarding foreign exchange fluctuation gains/losses, the ITAT ruled they form part of the sales proceeds and must be included in operating margin calculations for ALP determination. The AO was directed to include foreign exchange fluctuations in the operating margin of comparable companies. The decision favored the assessee on both exclusion of inappropriate comparables and inclusion of foreign exchange gains/losses. en-us Fri, 23 Nov 2012 00:00:00 +0530 Mon, 11 Aug 2025 14:59:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245173 ITAT Hyderabad upheld the DRP's view that extraordinary events like mergers impact profitability and require verification by the TPO, excluding such comparables if confirmed. Companies showing supernormal profits or questionable reputation were rightly excluded as comparables. The TPO's exclusion of companies with turnover vastly different from the assessee's was also upheld. The matter was remitted to the TPO for fresh ALP examination. Regarding foreign exchange fluctuation gains/losses, the ITAT ruled they form part of the sales proceeds and must be included in operating margin calculations for ALP determination. The AO was directed to include foreign exchange fluctuations in the operating margin of comparable companies. The decision favored the assessee on both exclusion of inappropriate comparables and inclusion of foreign exchange gains/losses. Case-Laws Income Tax Fri, 23 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245173