https://www.taxtmi.com/caselaws?id=363159 The High Court dismissed the Revenue's appeal, ruling that foreign exchange gain/loss should be considered operating in nature for transfer pricing analysis. It directed the AO/TPO to recompute the operating margin accordingly. The Court clarified that expenses for export turnover must be deducted from total turnover for section 10A deductions, referencing the HCL Technologies Ltd. case. The appeal lacked substantial legal questions, with the Court emphasizing that dissatisfaction with Tribunal findings is insufficient for appeal. The Revenue's appeal was deemed meritless and dismissed without costs. en-us Thu, 28 Jun 2018 00:00:00 +0530 Mon, 09 Jul 2018 08:25:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=363159 The High Court dismissed the Revenue's appeal, ruling that foreign exchange gain/loss should be considered operating in nature for transfer pricing analysis. It directed the AO/TPO to recompute the operating margin accordingly. The Court clarified that expenses for export turnover must be deducted from total turnover for section 10A deductions, referencing the HCL Technologies Ltd. case. The appeal lacked substantial legal questions, with the Court emphasizing that dissatisfaction with Tribunal findings is insufficient for appeal. The Revenue's appeal was deemed meritless and dismissed without costs. Case-Laws Income Tax Thu, 28 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=363159