https://www.taxtmi.com/caselaws?id=310985 ITAT Bangalore ruled in favor of the appellant on transfer pricing adjustments. The tribunal held that foreign exchange gains should be treated as operating items and either included in operating income or reduced from operating costs, following precedent from SAP Labs case and Delhi HC decision in Ameriprise India. Write-back of liabilities no longer required was also deemed operating in nature since original liabilities were operating expenses. The tribunal directed TPO to reconsider CG Vak Software Exports as a comparable company by properly computing employee costs, noting that employee cost disclosure issues prevented accurate filter application rather than actual failure to meet the 25% revenue threshold. en-us Fri, 07 Sep 2018 00:00:00 +0530 Thu, 30 Nov 2023 18:01:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310985 ITAT Bangalore ruled in favor of the appellant on transfer pricing adjustments. The tribunal held that foreign exchange gains should be treated as operating items and either included in operating income or reduced from operating costs, following precedent from SAP Labs case and Delhi HC decision in Ameriprise India. Write-back of liabilities no longer required was also deemed operating in nature since original liabilities were operating expenses. The tribunal directed TPO to reconsider CG Vak Software Exports as a comparable company by properly computing employee costs, noting that employee cost disclosure issues prevented accurate filter application rather than actual failure to meet the 25% revenue threshold. Case-Laws Income Tax Fri, 07 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310985