https://www.taxtmi.com/caselaws?id=456448 Foreign exchange fluctuation gains directly linked to export operations form part of operating income for transfer-pricing margin computation. Comparable companies must be excluded from a low-end IT-enabled services analysis where functional differences, extraordinary events, inorganic growth, inadequate segmental data, outsourcing-based operations, high-end services, or materially different scale and brand value undermine functional, asset and risk comparability. Applying these principles requires recomputation of the arm's-length price using a revised comparable set that reflects the tested party's actual business profile. en-us Thu, 11 Aug 2022 00:00:00 +0530 Thu, 25 Jul 2024 20:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456448 Foreign exchange fluctuation gains directly linked to export operations form part of operating income for transfer-pricing margin computation. Comparable companies must be excluded from a low-end IT-enabled services analysis where functional differences, extraordinary events, inorganic growth, inadequate segmental data, outsourcing-based operations, high-end services, or materially different scale and brand value undermine functional, asset and risk comparability. Applying these principles requires recomputation of the arm's-length price using a revised comparable set that reflects the tested party's actual business profile. Case-Laws Income Tax Thu, 11 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456448