https://www.taxtmi.com/caselaws?id=261512 The ITAT Delhi set aside the impugned order and remitted the matter to the TPO/AO for fresh determination of the ALP in the international transaction relating to IT-enabled data conversion services. Forex gain/loss from revenue transactions must be included in operating revenue/cost, while bank interest and charges are to be treated as non-operating expenses for both the assessee and comparables. Provisions for doubtful advances/debts are operating expenses and should be treated similarly for comparables. No risk adjustment was granted due to lack of evidence of higher risk by comparables. Several entities were excluded or included as comparables based on extraordinary financial events or lack of segment-wise data. Interest on delayed export proceeds must be considered for transfer pricing adjustment regardless of the agreement terms, with the interest rate determined by the currency of repayment. The matter was remanded for reconsideration accordingly. en-us Mon, 06 Jul 2015 00:00:00 +0530 Fri, 25 Jul 2025 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261512 The ITAT Delhi set aside the impugned order and remitted the matter to the TPO/AO for fresh determination of the ALP in the international transaction relating to IT-enabled data conversion services. Forex gain/loss from revenue transactions must be included in operating revenue/cost, while bank interest and charges are to be treated as non-operating expenses for both the assessee and comparables. Provisions for doubtful advances/debts are operating expenses and should be treated similarly for comparables. No risk adjustment was granted due to lack of evidence of higher risk by comparables. Several entities were excluded or included as comparables based on extraordinary financial events or lack of segment-wise data. Interest on delayed export proceeds must be considered for transfer pricing adjustment regardless of the agreement terms, with the interest rate determined by the currency of repayment. The matter was remanded for reconsideration accordingly. Case-Laws Income Tax Mon, 06 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261512