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Foreign Exchange Losses Included in Operating Expenses for Transfer Pricing Adjustments, Confirms Dispute Resolution Panel Decision.

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....TP adjustment - foreign exchange loss - part of operating expenses or not - Sales and forex losses incurred by the assessee are closely interlinked for this reason. Assessee in the sale price also giving AE benefit of forex fluctuation also. No infirmity in the direction of the LD DRP by including forex loss in the PLI computation of Assessee. - AT....

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Foreign Exchange Losses Included in Operating Expenses for Transfer Pricing Adjustments, Confirms Dispute Resolution Panel Decision.