https://www.taxtmi.com/caselaws?id=404446 The Tribunal set aside the final assessment order concerning the transfer pricing adjustment for the assessment year 2012-13, directing a fresh determination of the Arm's Length Price (ALP) of international transactions. The Tribunal found discrepancies in the Transfer Pricing Officer's (TPO) methodology, particularly the exclusion of foreign exchange gain from operating revenue. It emphasized that the safe harbour rules under Rule 10TA(k) are optional, and without opting for them, foreign exchange gain should be included in operating revenue. The appeal was partly allowed for statistical purposes, with no other grounds contested. en-us Wed, 20 Jan 2021 00:00:00 +0530 Tue, 29 Oct 2024 12:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404446 The Tribunal set aside the final assessment order concerning the transfer pricing adjustment for the assessment year 2012-13, directing a fresh determination of the Arm's Length Price (ALP) of international transactions. The Tribunal found discrepancies in the Transfer Pricing Officer's (TPO) methodology, particularly the exclusion of foreign exchange gain from operating revenue. It emphasized that the safe harbour rules under Rule 10TA(k) are optional, and without opting for them, foreign exchange gain should be included in operating revenue. The appeal was partly allowed for statistical purposes, with no other grounds contested. Case-Laws Income Tax Wed, 20 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404446