Foreign Exchange Gain Is Operating Income Under TNMM: ITAT Delhi

Advertisement Sara Sae Pvt. Ltd. Vs ACIT (ITAT Delhi) The Delhi ITAT partly allowed the assessee’s appeal against the assessment framed under Section 143(3) read with Sections 144C and 92CA(3) for AY 2013-14. The principal dispute concerned a transfer pricing adjustment of ₹3.65 crore relating to the sale of finished goods by the assessee’s Commodity Division to its associated enterprise in the USA. The assessee had benchmarked the transaction under the Transactional Net Margin Method (TNMM) using the operating profit to operating cost (OP/OC) ratio and claimed that the transa...