https://www.taxtmi.com/caselaws?id=772934 Foreign exchange gain directly linked to business receipts from associated enterprises is treated as part of operating revenue for profit level indicator purposes, and a selective approach that treats foreign exchange loss as operating while excluding corresponding gain is inconsistent. The safe harbour framework applies only where an eligible assessee voluntarily exercises the prescribed option; it cannot be invoked unilaterally by the revenue authorities. Applied to a captive IT service provider benchmarked under the transactional net margin method, these principles supported acceptance of the assessee's operating margin as computed and rejection of the reworked margin based on an inconsistent operating classification. en-us Wed, 28 May 2025 00:00:00 +0530 Mon, 16 Jun 2025 08:38:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772934 Foreign exchange gain directly linked to business receipts from associated enterprises is treated as part of operating revenue for profit level indicator purposes, and a selective approach that treats foreign exchange loss as operating while excluding corresponding gain is inconsistent. The safe harbour framework applies only where an eligible assessee voluntarily exercises the prescribed option; it cannot be invoked unilaterally by the revenue authorities. Applied to a captive IT service provider benchmarked under the transactional net margin method, these principles supported acceptance of the assessee's operating margin as computed and rejection of the reworked margin based on an inconsistent operating classification. Case-Laws Income Tax Wed, 28 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772934