https://www.taxtmi.com/caselaws?id=783577 Whether foreign exchange fluctuation arising from international transactions should be treated as operating in computing ALP was the dominant issue. Relying on its earlier ruling, the HC held that foreign exchange gain/loss attributable to trading or service items linked to AE transactions is integral to operating results, and where the inter-company agreement adopts a cost-plus pricing model, such fluctuation cannot be characterised as non-operating. Consequently, the ITAT correctly held that the AO erred in excluding foreign exchange loss from operating costs, and the TP adjustment was set aside in favour of the assessee. en-us Fri, 12 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783577 Whether foreign exchange fluctuation arising from international transactions should be treated as operating in computing ALP was the dominant issue. Relying on its earlier ruling, the HC held that foreign exchange gain/loss attributable to trading or service items linked to AE transactions is integral to operating results, and where the inter-company agreement adopts a cost-plus pricing model, such fluctuation cannot be characterised as non-operating. Consequently, the ITAT correctly held that the AO erred in excluding foreign exchange loss from operating costs, and the TP adjustment was set aside in favour of the assessee. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783577