https://www.taxtmi.com/caselaws?id=310692 ITAT Bangalore ruled on transfer pricing adjustments for an IT services company. The tribunal held that foreign exchange gains arising from software development service realization must be included in operating revenue as they occur in normal business course. However, donations should be excluded from operating revenue as they are not part of normal business activities. Regarding comparable selection, the tribunal excluded Accentia Technologies Ltd. due to amalgamation impact, eClerx Services Ltd. for providing functionally different high-end specialized services, and remanded Cosmic Global Ltd.'s comparability issue to TPO for fresh examination given insufficient prior consideration of its low-volume BPO segment. en-us Fri, 24 Apr 2015 00:00:00 +0530 Tue, 07 Nov 2023 21:48:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310692 ITAT Bangalore ruled on transfer pricing adjustments for an IT services company. The tribunal held that foreign exchange gains arising from software development service realization must be included in operating revenue as they occur in normal business course. However, donations should be excluded from operating revenue as they are not part of normal business activities. Regarding comparable selection, the tribunal excluded Accentia Technologies Ltd. due to amalgamation impact, eClerx Services Ltd. for providing functionally different high-end specialized services, and remanded Cosmic Global Ltd.'s comparability issue to TPO for fresh examination given insufficient prior consideration of its low-volume BPO segment. Case-Laws Income Tax Fri, 24 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310692