https://www.taxtmi.com/caselaws?id=262735 Transfer pricing analysis addresses inclusion or exclusion of specific service-providing entities as comparables for determining arms length price under TNMM: entities with comparable functional profile or segmental data must be included, while companies whose ITES results are inseparable from product revenues or whose activities rely on significant intangibles should be excluded. Foreign exchange gains/losses arising from revenue transactions must be treated as operating revenue/cost for both the taxpayer and comparables. Interest adjustments for delayed invoice realization are assessed transactionally and are not justified where invoices were realized within the contractual 60-day period. en-us Fri, 14 Aug 2015 00:00:00 +0530 Sat, 24 Jan 2026 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262735 Transfer pricing analysis addresses inclusion or exclusion of specific service-providing entities as comparables for determining arms length price under TNMM: entities with comparable functional profile or segmental data must be included, while companies whose ITES results are inseparable from product revenues or whose activities rely on significant intangibles should be excluded. Foreign exchange gains/losses arising from revenue transactions must be treated as operating revenue/cost for both the taxpayer and comparables. Interest adjustments for delayed invoice realization are assessed transactionally and are not justified where invoices were realized within the contractual 60-day period. Case-Laws Income Tax Fri, 14 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262735