https://www.taxtmi.com/caselaws?id=273805 The Tribunal held that foreign exchange fluctuations gain should be considered as operating in nature for transfer pricing analysis. It directed the Assessing Officer to include these fluctuations in the operating profit for both the assessee and comparable companies. The Tribunal also instructed the Transfer Pricing Officer to consider the benefit of tolerance range if the price falls within +/-5% of the comparable price. The imposition of interest under sections 234B and 234C was deemed mandatory and consequential. The Tribunal upheld the CIT (A)'s decisions on risk adjustment, treatment of foreign exchange gain/loss, and certain expense exclusions, partially allowing both the assessee's and revenue's appeals. en-us Wed, 19 Oct 2016 00:00:00 +0530 Mon, 16 Jul 2018 08:05:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273805 The Tribunal held that foreign exchange fluctuations gain should be considered as operating in nature for transfer pricing analysis. It directed the Assessing Officer to include these fluctuations in the operating profit for both the assessee and comparable companies. The Tribunal also instructed the Transfer Pricing Officer to consider the benefit of tolerance range if the price falls within +/-5% of the comparable price. The imposition of interest under sections 234B and 234C was deemed mandatory and consequential. The Tribunal upheld the CIT (A)'s decisions on risk adjustment, treatment of foreign exchange gain/loss, and certain expense exclusions, partially allowing both the assessee's and revenue's appeals. Case-Laws Income Tax Wed, 19 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273805