ITAT ruled in favor of the tax authority on TP Adjustment for foreign exchange gains and engineering services. Assessee's appeal dismissed.

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....The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional Net Margin Method (TNMM) while the Transfer Pricing Officer (TPO) applied Resale Price Method (RPM). The Dispute Resolution Panel (DRP) granted partial relief to the assessee, which was followed by the Assessing Officer in the assessment order. The Tribunal found no evidence to challenge the Assessing Officer's or TPO's findings, thus upholding the assessment order and dismissing the assessee's appeal.....