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    <title>Transfer Pricing Adjustments: Comparable Selection Criteria and Foreign Exchange Gains Treated as Operating Income</title>
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    <description>ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee&#039;s ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.</description>
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      <description>ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee&#039;s ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.</description>
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