https://www.taxtmi.com/caselaws?id=772039 ITAT Pune held that foreign exchange gains of Rs. 17.02 crore on trade receivables from associated enterprise should be treated as operating income for calculating operating profit margin in transfer pricing analysis. Regarding comparable selection, the tribunal excluded four comparables (Manipal Digital Systems, C E S Ltd, M P S Ltd, Domex E-Data) as functionally different, retained Tech Mahindra Business Services as good comparable, excluded three comparables based on prior tribunal precedent, and rejected inclusion of Global Healthcare Billing and Digicall Global as comparables due to functional differences and extraordinary events. en-us Fri, 30 May 2025 00:00:00 +0530 Tue, 03 Jun 2025 08:50:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772039 ITAT Pune held that foreign exchange gains of Rs. 17.02 crore on trade receivables from associated enterprise should be treated as operating income for calculating operating profit margin in transfer pricing analysis. Regarding comparable selection, the tribunal excluded four comparables (Manipal Digital Systems, C E S Ltd, M P S Ltd, Domex E-Data) as functionally different, retained Tech Mahindra Business Services as good comparable, excluded three comparables based on prior tribunal precedent, and rejected inclusion of Global Healthcare Billing and Digicall Global as comparables due to functional differences and extraordinary events. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772039