https://www.taxtmi.com/caselaws?id=306274 The Tribunal upheld the exclusion of Accentia Technologies Ltd. from the comparables in the Transfer Pricing study, citing factors like dissimilar business models and lack of segmental data. It dismissed the Revenue's challenge on accepting additional evidence under Rule 46A due to lack of supporting evidence. Additionally, the Tribunal directed the Revenue to treat foreign exchange gains/losses as part of operational income, not as non-operating, supporting the appellant's position. The Tribunal ultimately dismissed the Revenue's appeal and allowed the Cross Objection of the assessee, emphasizing the correct treatment of foreign exchange gains/losses and the exclusion of Accentia Technologies Ltd. from the comparables. en-us Wed, 03 Jul 2019 00:00:00 +0530 Fri, 20 Jan 2023 07:16:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306274 The Tribunal upheld the exclusion of Accentia Technologies Ltd. from the comparables in the Transfer Pricing study, citing factors like dissimilar business models and lack of segmental data. It dismissed the Revenue's challenge on accepting additional evidence under Rule 46A due to lack of supporting evidence. Additionally, the Tribunal directed the Revenue to treat foreign exchange gains/losses as part of operational income, not as non-operating, supporting the appellant's position. The Tribunal ultimately dismissed the Revenue's appeal and allowed the Cross Objection of the assessee, emphasizing the correct treatment of foreign exchange gains/losses and the exclusion of Accentia Technologies Ltd. from the comparables. Case-Laws Income Tax Wed, 03 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306274