https://www.taxtmi.com/caselaws?id=794104 Foreign exchange gain from regular business activity was treated as operating income for transfer pricing purposes, and the assessee's profit-based allocation of common expenses was accepted; the turnover-based allocation and the objection to the selected comparables were rejected, so the matter was remitted for fresh benchmarking. Interest on borrowed funds advanced partly as an interest-bearing loan to a wholly owned subsidiary was held deductible under section 57(iii), and the related disallowance was deleted. The penalty ground under section 271(1)(c) was not adjudicated because it had not matured and was dismissed as premature. en-us Mon, 29 Jun 2026 00:00:00 +0530 Tue, 30 Jun 2026 07:22:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794104 Foreign exchange gain from regular business activity was treated as operating income for transfer pricing purposes, and the assessee's profit-based allocation of common expenses was accepted; the turnover-based allocation and the objection to the selected comparables were rejected, so the matter was remitted for fresh benchmarking. Interest on borrowed funds advanced partly as an interest-bearing loan to a wholly owned subsidiary was held deductible under section 57(iii), and the related disallowance was deleted. The penalty ground under section 271(1)(c) was not adjudicated because it had not matured and was dismissed as premature. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794104