https://www.taxtmi.com/caselaws?id=261253 An additional ground on operating profit margin computation could be admitted where the relevant figures were already on record and the issue was arithmetical, leading to recomputation on correct operating profit and operating cost figures. Foreign exchange gain or loss arising directly from business transactions was treated as an operating item under TNMM, and it could not be excluded merely as non-operating; the Safe Harbour Rules were noted as not applicable retrospectively to the year in question. A comparable was also directed for exclusion subject to verification where the employee cost filter was not satisfied, and prior inclusion in the transfer pricing study did not bar challenge because there is no estoppel against law. en-us Fri, 29 May 2015 00:00:00 +0530 Tue, 07 Jul 2015 06:41:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261253 An additional ground on operating profit margin computation could be admitted where the relevant figures were already on record and the issue was arithmetical, leading to recomputation on correct operating profit and operating cost figures. Foreign exchange gain or loss arising directly from business transactions was treated as an operating item under TNMM, and it could not be excluded merely as non-operating; the Safe Harbour Rules were noted as not applicable retrospectively to the year in question. A comparable was also directed for exclusion subject to verification where the employee cost filter was not satisfied, and prior inclusion in the transfer pricing study did not bar challenge because there is no estoppel against law. Case-Laws Income Tax Fri, 29 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261253