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TMI Blog2021 (2) TMI 465X X X X Extracts X X X X X X X X Extracts X X X X ..... ORE] we are of the opinion that foreign exchange gain arising from the fluctuation of foreign exchange has to be considered as operative in nature while computing the PLI. The CIT (Appeals) has taken a correct view holding that the foreign exchange gain earned having nexus with international transaction as part of operating income. This ground of appeal of revenue is dismissed. - IT(TP)A No. 11 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nature. 3. Whether on facts and in circumstances of the case and in law, the learned CIT (Appeals) is right in accepting the additional evidences submitted during the course of appellate proceeding without giving an opportunity to the Assessing Officer to examine the fresh evidences as required under Rule 46A. 4. For thee and such other grounds that may be urged at the time of hearing, i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case of M/s. Fidelity Business Services India Pvt. Ltd. Vs. ACIT in IT(TP)A No. 308/Bang/2017 dt. 17.12.2020 wherein in para 15 held as under: 15. As far as ground No. 15 raised by the assessee is concerned, it is a consistent view of the Bangalore Benches of ITAT that foreign exchange gain has to be taken as part of the operating profits to the extent that it has nexus with the intern ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... action as part of operating income. Taking a consistent view, we are of the opinion that foreign exchange gain arising from the fluctuation of foreign exchange has to be considered as operative in nature while computing the PLI. The CIT (Appeals) has taken a correct view holding that the foreign exchange gain earned having nexus with international transaction as part of operating income. This ..... X X X X Extracts X X X X X X X X Extracts X X X X
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