https://www.taxtmi.com/highlights?id=95175 Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC en-us Thu, 18 Dec 2025 08:02:00 +0530 Thu, 18 Dec 2025 08:02:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95175 Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC Highlights Income Tax Thu, 18 Dec 2025 08:02:00 +0530 https://www.taxtmi.com/highlights?id=95175