TMI Blog2018 (1) TMI 1453X X X X Extracts X X X X X X X X Extracts X X X X ..... that so far as these two comparables are concerned, the findings with respect to functional similarity of these entities vis-a-vis the assessee are borne out from the record. Inclusion of SIP Technologies and Export Limited as a comparable is concerned, the approach adopted by the ITAT – of ignoring the low margin, is in consonance with this Court’s judgment. However, with respect to the exclus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... :- 31-1-2018 - Mr. S. Ravindra Bhat And Mr. A. K. Chawla, JJ. Mr. Zoheb Hossain, Sr. Standing Counsel with Mr. Deepak Anand, Jr. Standing Counsel For The Appellant. Mr. Aditya Vohra, Advocate For The Respondent. ORDER The Revenue in its appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act ) is aggrieved by the exclusion of four comparab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r question urged is with respect to treatment of forex gain/loss. On this issue, this Court has ruled against the Revenue holding that the forex gain/loss cannot be treated as a part of income and made the subject matter of adjustment, in the cases of Principal Commissioner of Income Tax v. Cashedge India Pvt. Ltd., ITA 279/2016, decided on 04.05.2016 as well as Principal Commissioner of Income Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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