https://www.taxtmi.com/caselaws?id=458317 The ITAT Delhi ruled in favor of the taxpayer on multiple transfer pricing issues. The tribunal held that foreign exchange gains must be included in operating income when computing operating margins for both the taxpayer and comparable companies. Three comparable companies (ANG Industries Ltd., Elofic, and WABCO) were excluded due to diversified activities, lack of segmental reporting, and significant R&D activities respectively. The tribunal remanded issues regarding depreciation adjustments and cash profit analysis back to the TPO for fresh consideration, directing verification of comparable company margins and reconsideration based on previous tribunal decisions and the taxpayer's own case precedents. en-us Wed, 04 Jul 2018 00:00:00 +0530 Mon, 21 Oct 2024 22:02:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458317 The ITAT Delhi ruled in favor of the taxpayer on multiple transfer pricing issues. The tribunal held that foreign exchange gains must be included in operating income when computing operating margins for both the taxpayer and comparable companies. Three comparable companies (ANG Industries Ltd., Elofic, and WABCO) were excluded due to diversified activities, lack of segmental reporting, and significant R&D activities respectively. The tribunal remanded issues regarding depreciation adjustments and cash profit analysis back to the TPO for fresh consideration, directing verification of comparable company margins and reconsideration based on previous tribunal decisions and the taxpayer's own case precedents. Case-Laws Income Tax Wed, 04 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458317