Transfer Pricing: Forex Fluctuation is Operating Income/Cost in Cost-Plus Transactions

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...