https://www.taxtmi.com/caselaws?id=274068 The Tribunal ruled in favor of the assessee, upholding the inclusion of foreign exchange gain in operating revenue for computing the arm's length price (ALP) in an international transaction. It determined that the foreign exchange gain was directly linked to the sale proceeds realized by the assessee and should be considered as part of operating revenue, rejecting the Revenue's argument that the nexus with the business activity was not established. The decision clarified the treatment of foreign exchange gains in ALP calculations, emphasizing the direct connection between such gains and the taxpayer's business activity. en-us Fri, 29 May 2015 00:00:00 +0530 Fri, 27 Jul 2018 10:42:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274068 The Tribunal ruled in favor of the assessee, upholding the inclusion of foreign exchange gain in operating revenue for computing the arm's length price (ALP) in an international transaction. It determined that the foreign exchange gain was directly linked to the sale proceeds realized by the assessee and should be considered as part of operating revenue, rejecting the Revenue's argument that the nexus with the business activity was not established. The decision clarified the treatment of foreign exchange gains in ALP calculations, emphasizing the direct connection between such gains and the taxpayer's business activity. Case-Laws Income Tax Fri, 29 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274068