Export Incentives Are Operating Revenue for Transfer Pricing, Contrary to DRP's Initial Misjudgment in Tax Assessment.

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....TP Adjustment - Treatment of export incentives as non-operating - it is not any initial period of operations of the assessee as taken note of by the DRP. It appears that the DRP mixed up the facts of some other case, which eventually resulted in miscarriage of justice. Thus we are of the considered opinion that the amount of export incentives is liable to be considered as part of operating revenue. - AT....