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2016 (1) TMI 1276 - DELHI HIGH COURT
TPA - foreign exchange fluctuation treated as operating expenses/income - Held that:- The Safe Harbour Notification dated 18th September 2013 relied upon by the Revenue is prospective and did not apply to the AY in question. Even otherwise the Court finds that the decisions relied upon by the ITAT in the impugned order covers this issue in favour of the Assessee as far as the AY in question is concerned. Consequently, the Court declines to frame any question on the issue.
Rejecting the comparables - Held that:- As far as this question the Court finds that the ITAT has undertaken a detailed factual analysis and given cogent reasons for the exclusion of the comparables in question. The Court is not persuaded to hold that any substantial question of law arises as regards the said issue.