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

Foreign Exchange Losses Must Be Included in Transfer Pricing Calculations for Cost-Plus Entities, Rules Panel.

February 15, 2021

Case Laws Income Tax AT

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

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

Foreign Exchange Losses Must Be Included in Transfer Pricing Calculations for Cost-Plus Entities, Rules Panel.

February 15, 2021

Case Laws Income Tax AT

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