https://www.taxtmi.com/caselaws?id=369429 Transfer pricing analysis under TNMM addressed whether foreign exchange gain linked to service transactions should form part of operating income, whether a 75% export-sales filter was appropriate, whether specific companies were valid comparables, and whether risk and working capital adjustments were justified. Foreign exchange gain was to be recomputed as operating income if linked to operations. The export-sales filter was upheld on the assessee's facts. iGATE Solutions Ltd. was excluded because of high related-party transactions, amalgamation, and lack of segmental data, while Capgemini Business Services (India) Pvt. Ltd. and e4e Healthcare Business Services Ltd. were retained. Risk adjustment was denied for want of a credible quantification method, and working capital adjustment was not entertained as it was not raised below. en-us Mon, 15 Oct 2018 00:00:00 +0530 Sat, 27 Oct 2018 07:52:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369429 Transfer pricing analysis under TNMM addressed whether foreign exchange gain linked to service transactions should form part of operating income, whether a 75% export-sales filter was appropriate, whether specific companies were valid comparables, and whether risk and working capital adjustments were justified. Foreign exchange gain was to be recomputed as operating income if linked to operations. The export-sales filter was upheld on the assessee's facts. iGATE Solutions Ltd. was excluded because of high related-party transactions, amalgamation, and lack of segmental data, while Capgemini Business Services (India) Pvt. Ltd. and e4e Healthcare Business Services Ltd. were retained. Risk adjustment was denied for want of a credible quantification method, and working capital adjustment was not entertained as it was not raised below. Case-Laws Income Tax Mon, 15 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369429