Foreign exchange gain/loss arising out of revenue transactions is required to be considered as an item of operating revenue/cost

Brief of the case:

In the case of Ameriprise India Pvt. Ltd. Vs. ACIT Delhi Bench of ITAT held that the AO was not justified in considering forex loss as non-operating cost as against the assessee’s claim of operating cost. ITAT further held that the amount of foreign exchange gain/loss arising out of revenue transactions is required to be considered as an item of operating revenue/cost, both of the assessee as well as comparables. Apart from this ITAT also give its finding on the inclusion/exclusion of certain companies in/from the list of comparables.

Facts of the case:

• Assessee is a wholly owned subsidiary of Ameriprise, US, which parent company is engaged in the business of insurance, annuities, asset management and brokerage.

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