Foreign Exchange Gains/Losses as Operating Income; Transfer Pricing Comparables Reviewed for Consistency.

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....HELD: DRP excluded forex losses and gains from operating income computation based on safe harbor rules. However, both being of similar nature, forex gains to be treated as operating income like losses. Thirdware Solutions Ltd.'s inclusion or exclusion as comparable remitted to TPO for adjudication based on substantiation. Akshay Software Technologies Ltd. to be accepted as comparable. Infosys BPO Ltd. excluded as services offered not comparable to assessee's routine services. BNR Udyog Ltd. excluded as engaged in KPO services. Informed Technologies India Ltd. to be included as comparable under ITeS segment. Ace BPO Services Ltd.'s inclusion directed if current data available. Disallowance u/s 40(a)(i) for want of TDS u/s 195 on payments to GTE-Overseas Corporation restored to AO for consistent stand.....