https://www.taxtmi.com/caselaws?id=434966 The ITAT Hyderabad ruled in favor of the assessee on multiple issues. The tribunal held that no transfer pricing adjustment was warranted on equity investment in a wholly owned subsidiary, as the assessee had provided adequate documentation proving it was equity investment, not a loan requiring ALP interest computation. The tribunal directed the AO to verify export turnover calculations for Section 10A deduction based on actual foreign exchange realizations. Regarding foreign exchange fluctuation gains, the matter was restored to the AO to verify potential double taxation. The tribunal upheld the DRP's decision to exclude telecommunication charges from total turnover for Section 10B deduction computation, dismissing the Revenue's appeal on this issue. en-us Wed, 22 Feb 2023 00:00:00 +0530 Mon, 30 Jun 2025 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434966 The ITAT Hyderabad ruled in favor of the assessee on multiple issues. The tribunal held that no transfer pricing adjustment was warranted on equity investment in a wholly owned subsidiary, as the assessee had provided adequate documentation proving it was equity investment, not a loan requiring ALP interest computation. The tribunal directed the AO to verify export turnover calculations for Section 10A deduction based on actual foreign exchange realizations. Regarding foreign exchange fluctuation gains, the matter was restored to the AO to verify potential double taxation. The tribunal upheld the DRP's decision to exclude telecommunication charges from total turnover for Section 10B deduction computation, dismissing the Revenue's appeal on this issue. Case-Laws Income Tax Wed, 22 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434966