Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights February 2021 Year 2021 This

TP Adjustment - When foreign exchange loss is to form part of ...

Case Laws     Income Tax

February 15, 2021

TP Adjustment - When foreign exchange loss is to form part of the total base of the taxpayer for the purpose of charging a mark up to its AEs as it drives income from its overseas AEs and it being a cost plus entity, the taxpayer earns foreign exchange loss incurred if any, foreign exchange fluctuation is operating in nature in order to compute margins, hence ld. DRP/TPO/AO has erred in treating foreign exchange loss as non-operating item. - AT

View Source

 


 

You may also like:

  1. TP Adjustment - Reduction of economic adjustment on foreign exchange fluctuation loss - in principle, the foreign exchange fluctuation loss adjustment has to be given...

  2. Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

  3. The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

  4. Export turnover brought into India does not qualify as 75% of total turnover for claiming exemption u/s 10A. Expenditure incurred in foreign exchange must be excluded...

  5. Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the...

  6. Export of service - receipt of consideration in convertible foreign exchange - The said debit of foreign exchange by the UK bank and consequent credit in Indian rupee in...

  7. 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....

  8. Nature of loss - speculative transaction - When the assessee is not dealer in foreign exchange and as a part of his normal business activity, enters into hedging...

  9. Definitions - Regulation 2 of the FOREIGN EXCHANGE MANAGEMENT (FOREIGN EXCHANGE DERIVATIVE CONTRACTS) REGULATIONS, 2000 as amended

  10. TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator...

  11. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

  12. Disallowance of gross MTM loss - the obligation accrued against the taxpayer the minute it entered into forward foreign exchange contracts. So, the forward foreign...

  13. Scope of Section 14A - Disallowance of carried forward losses - whether losses are forming part of total income in view of Sec.14A as the same is result of profits and...

  14. The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

  15. TP adjustment - Direction in remand proceeding - Customs Duty Adjustment, Air Freight Adjustment and Foreign Exchange Adjustment - If the Tribunal has fixed how such...

 

Quick Updates:Latest Updates