https://www.taxtmi.com/caselaws?id=462398 The Tribunal dismissed Revenue's appeal regarding exclusion of foreign exchange gains/losses from operating income for Arm's Length Price determination. Following precedent in INA Bearings India Pvt. Ltd., the Tribunal held that forex gains/losses arising from international trading transactions are integral to export proceeds and must be included in operating revenue/cost for transfer pricing analysis. Revenue's reliance on safe harbour rules was rejected as they were inapplicable for the relevant assessment year. The Tribunal allowed Revenue's grounds 3-4 as conceded by assessee and dismissed assessee's cross objection as infructuous. en-us Thu, 21 Nov 2019 00:00:00 +0530 Thu, 19 Jun 2025 18:54:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462398 The Tribunal dismissed Revenue's appeal regarding exclusion of foreign exchange gains/losses from operating income for Arm's Length Price determination. Following precedent in INA Bearings India Pvt. Ltd., the Tribunal held that forex gains/losses arising from international trading transactions are integral to export proceeds and must be included in operating revenue/cost for transfer pricing analysis. Revenue's reliance on safe harbour rules was rejected as they were inapplicable for the relevant assessment year. The Tribunal allowed Revenue's grounds 3-4 as conceded by assessee and dismissed assessee's cross objection as infructuous. Case-Laws Income Tax Thu, 21 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462398