Forex loss from ECB & capital transactions is non-operating for TP purposes

Poclain Hydraulics Pvt. Ltd. Vs DCIT (ITAT Chennai) The Income Tax Appellate Tribunal (ITAT), Chennai, partly allowed the assessee’s appeal for statistical purposes in a transfer pricing dispute relating to Assessment Year 2021-22. The assessee, a 100% export-oriented company engaged in manufacturing hydraulic motors and motor components, had declared income of ₹12.24 crore. During scrutiny, the Assessing Officer (AO) referred the international transactions to the Transfer Pricing Officer (TPO), who initially proposed an upward transfer pricing adjustment of ₹12.93 crore, later revis...