https://www.taxtmi.com/caselaws?id=798348 Transfer-pricing analysis for ITES/BPO services requires comparables to satisfy functional comparability and Rule 10B(4) data requirements: R Systems International may be included only where publicly available quarterly data permits alignment, while product-development, KPO, extraordinary-acquisition, and functional differences support exclusion of unsuitable companies. Expenditure disallowance relating to exempt income does not arise where no exempt income is earned in the relevant year. Under TNMM, foreign-exchange gain or loss directly arising from ordinary trading transactions forms part of operating results; foreign-exchange loss must therefore be included in operating costs, notwithstanding the scale of exchange-rate movement or the timing of receipts and payments under mercantile accounting. en-us Wed, 02 Sep 2026 00:00:00 +0530 Sat, 05 Sep 2026 08:44:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798348 Transfer-pricing analysis for ITES/BPO services requires comparables to satisfy functional comparability and Rule 10B(4) data requirements: R Systems International may be included only where publicly available quarterly data permits alignment, while product-development, KPO, extraordinary-acquisition, and functional differences support exclusion of unsuitable companies. Expenditure disallowance relating to exempt income does not arise where no exempt income is earned in the relevant year. Under TNMM, foreign-exchange gain or loss directly arising from ordinary trading transactions forms part of operating results; foreign-exchange loss must therefore be included in operating costs, notwithstanding the scale of exchange-rate movement or the timing of receipts and payments under mercantile accounting. Case-Laws Income Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798348