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2016 (5) TMI 631 - ITAT PUNETransfer pricing adjustment - Profit Level Indicator (PLI) - adjustment on account of foreign currency loss to the profit margins which are adopted for working out the PLI - Held that:- While computing PLI for the year under consideration, the loss arising on account of foreign exchange fluctuation to the tune of ₹ 35,31,729/- is to be excluded. However, the loss arising on account of export proceeds realized from exports of relevant year are to be considered while computing PLI of the assessee. In view thereof, we modify the order of CIT(A) and direct the Assessing Officer to re-compute the PLI in the hands of assessee and foreign exchange fluctuation losses of the earlier years are to be kept out of calculation of PLI for the year under consideration. No adjustment is to be made on account of depreciation in the hands of assessee while computing PLI of the assessee.
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