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2018 (3) TMI 296 - AT - Income TaxNon-consideration of the foreign exchange gains as operational income for the purpose of computing the PLI - Held that:- We find that Hon’ble Delhi High Court in the case of BC Management Services (P) Ltd., (supra), has held that the “Safe Harbour Rules” which were notified by the Revenue authorities came into force in 2013 and therefore not applicable to A.Y. 2011- 12. Before us, Revenue has not placed any contrary binding decision in its support. Thus TPO and DRP has erred in considering the foreign exchange gain to be as non-operational income by relying solely on Rule 10TA. We therefore set aside the order of TPO and direct that the foreign exchange gains to be considered as operational income for the purpose of computation of PLI. - Decided in favour of assessee
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