TMI Blog2015 (5) TMI 1154X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee was in respect of the sale proceeds which the assessee had to realize. In such circumstances, it cannot be contended by the Revenue that the nexus of the foreign exchange gain with the business activity of the tax payer has not been ascertained by the DRP. We therefore do not find any merits in this appeal by the Revenue. Consequently the same is dismissed. - IT(TP)A No.81/Bang/2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny engaged in the business of manufacture of aluminum radiator and air-conditioners for cars and multiutility vehicles. The assessee entered into an international transaction with its AE viz., Denso, Japan. The arm s length price (ALP) in respect of the international transaction carried out by the assessee with its AE had to be determined in view of the provisions of section 92 of the Act. The nar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ore Bench in the case of SAP Labs India Pvt. Ltd. v. ACIT (2011) 44 SOT 156, wherein it was held that foreign exchange fluctuation gain is nothing but integral part of the sale proceeds of the assessee carrying on export business and that the same should be treated as operating income. The CIT(Appeals), following the aforesaid decision, directed the AO to compute margin of the assessee and compara ..... X X X X Extracts X X X X X X X X Extracts X X X X
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