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Transfer Pricing: Forex Fluctuation is Operating Income/Cost in Cost-Plus Transactions
Case Law Details
- Case Name
- PCIT Vs Steria India Pvt. Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-11
- Courts
- All High Courts, Delhi High Court
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PCIT Vs Steria India Pvt. Ltd. (Delhi High Court)
Transfer Pricing Appeal Dismissed as Issues Already Covered by Precedent; Forex Fluctuation Treated as Operating Income/Cost in Cost-Plus Transactions; High Brand Value and Intangibles Justify Exclusion of Transfer Pricing Comparables; Amalgamation and Extraordinary Events Make Companies Non-Comparable for TP; Software Product and R&D Companies Not Comparable to Service Providers; No Substantial Question of Law Where ITAT Follows Settled Transfer Pricing Law; Revenue Appeal Also Rejected Due to 1265-Day Delay in Re-Filing
The Delhi High Cou...
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