Foreign Exchange Gain Is Operating Income as It Arises from Export of Services

Vaildor Capital India Pvt. Ltd. Vs ITO (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, partly allowed the assessee’s appeal arising from an assessment under Section 143(3) of the Income Tax Act, 1961 for Assessment Year 2010-11 involving transfer pricing adjustments. The dispute related to the determination of the Arm’s Length Price (ALP) for international transactions of IT-enabled services rendered by the assessee to its overseas associated enterprise. The issues pressed before the Tribunal concerned the treatment of foreign exchange fluctuation gains, grant of working capi...