Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (2) TMI 465 - AT - Income TaxTP Adjustment - ALP Determination - Forex gain earned form Software Development Services - considered operative in nature while computing the PLI - HELD THAT:- As relying on M/S. FIDELITY BUSINESS SERVICES INDIA PVT. LTD. [2020 (12) TMI 728 - ITAT BANGALORE] we are of the opinion that foreign exchange gain arising from the fluctuation of foreign exchange has to be considered as operative in nature while computing the PLI. The CIT (Appeals) has taken a correct view holding that the foreign exchange gain earned having nexus with international transaction as part of operating income. This ground of appeal of revenue is dismissed.
|