Foreign exchange gain/ loss from ordinary course of business is operating cost/ revenue

Dana India Pvt. Ltd. Vs DCIT (ITAT Pune)

ITAT Pune held that foreign exchange gain/loss which has arisen from exports/imports of the product/materials which are in the ordinary course of business of the assesses are included as operating cost.

Facts-

The issue in the present case is that the assesse treated the Foreign Exchange fluctuation gain as an operating revenue, whereas, the Transfer Pricing Officer (TPO)/Assessing Officer (AO), based on their decision on Rule 10TA of the Income Tax Rules of 1962, considered the fluctuation gain as non-operating revenue, resulting and influence in the assessor’s capacity to calculate its profit level indicator (PLI).

Conclusion-

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