https://www.taxtmi.com/caselaws?id=768034 ITAT Delhi ruled on transfer pricing adjustments regarding comparable selection for BPO services. The tribunal excluded Cosmic Global as it failed the 75% export sales filter with 0% export revenue from BPO services, and rejected Eclerx Services for functional dissimilarity while including TCS e-Serve as functionally comparable. The tribunal directed foreign exchange gains be treated as operating income rather than non-operating, finding such gains directly related to ITES revenue from associated enterprises. ICRA Online was retained as comparable meeting the 87% export earnings threshold, while Motif India Infotech was included due to insufficient grounds for rejection by TPO. en-us Wed, 26 Mar 2025 00:00:00 +0530 Sat, 29 Mar 2025 08:15:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768034 ITAT Delhi ruled on transfer pricing adjustments regarding comparable selection for BPO services. The tribunal excluded Cosmic Global as it failed the 75% export sales filter with 0% export revenue from BPO services, and rejected Eclerx Services for functional dissimilarity while including TCS e-Serve as functionally comparable. The tribunal directed foreign exchange gains be treated as operating income rather than non-operating, finding such gains directly related to ITES revenue from associated enterprises. ICRA Online was retained as comparable meeting the 87% export earnings threshold, while Motif India Infotech was included due to insufficient grounds for rejection by TPO. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768034