https://www.taxtmi.com/caselaws?id=462943 The ITAT Delhi held that the assessee's products, being non-core auto components (horns), are not comparable to the core auto component manufacturers relied upon by the TPO. The distinction between core and non-core components is significant for FAR analysis and pricing, and the DRP's rejection of the TPO's comparables was upheld. Consequently, the transfer pricing adjustment based on those comparables was deleted. Regarding the forex loss treatment, the tribunal ruled that forex gains/losses are not operating income/costs and should be excluded from operating profit calculations for PLI determination. The DRP's direction to treat forex loss as non-operating was accepted, and the revenue's grounds on this issue were dismissed. en-us Fri, 10 May 2019 00:00:00 +0530 Sat, 26 Jul 2025 08:40:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462943 The ITAT Delhi held that the assessee's products, being non-core auto components (horns), are not comparable to the core auto component manufacturers relied upon by the TPO. The distinction between core and non-core components is significant for FAR analysis and pricing, and the DRP's rejection of the TPO's comparables was upheld. Consequently, the transfer pricing adjustment based on those comparables was deleted. Regarding the forex loss treatment, the tribunal ruled that forex gains/losses are not operating income/costs and should be excluded from operating profit calculations for PLI determination. The DRP's direction to treat forex loss as non-operating was accepted, and the revenue's grounds on this issue were dismissed. Case-Laws Income Tax Fri, 10 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462943