https://www.taxtmi.com/caselaws?id=314084 ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that foreign exchange fluctuation gains should be treated as operating revenue, and with exclusion of six functionally dissimilar comparable companies, no transfer pricing adjustment was required as the assessee fell within the +/-5% tolerance range under Section 92C(2). The tribunal allowed deduction under Section 10A for interest income on fixed deposits and forex gains in EEFC account, treating them as business income of the export-oriented undertaking. Additionally, the tribunal directed the AO to grant TDS credit and allow deduction for education cess as business expenditure. en-us Wed, 15 Sep 2021 00:00:00 +0530 Thu, 16 May 2024 18:56:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314084 ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that foreign exchange fluctuation gains should be treated as operating revenue, and with exclusion of six functionally dissimilar comparable companies, no transfer pricing adjustment was required as the assessee fell within the +/-5% tolerance range under Section 92C(2). The tribunal allowed deduction under Section 10A for interest income on fixed deposits and forex gains in EEFC account, treating them as business income of the export-oriented undertaking. Additionally, the tribunal directed the AO to grant TDS credit and allow deduction for education cess as business expenditure. Case-Laws Income Tax Wed, 15 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314084