TMI Blog2013 (11) TMI 194X X X X Extracts X X X X X X X X Extracts X X X X ..... ture - It was only the acquisition of information, guidance or payment for consultancy which is received by way of drawing and design and explains how the production process was to be carried on which will result into only revenue expenditure and not for acquisition of any capital asset - The amendment w.e.f 1.4.98 had not alter the situation - Whatever are capital expenditure which were in the nature of intangible assets and which were not eligible for depreciation earlier, were only now eligible for claim of depreciation u/s 32 but cannot be expended to mean that what were revenue expenditure was now to be treated as capital expenditure after the amendment Thus, the amount being revenue expenditure, was allowable as such u/s 37(2) of the Act. Relying upon Commissioner Of Income-Tax, Bombay City I Versus Tata Engineering And Locomotive Co. Pvt Limited [1979 (2) TMI 20 - BOMBAY High Court ] - The assessee merely acquired technical know-how so that it could manufacture the products as required but such know-how was not in relation to setting up of the plant or machinery - It will thus amount to acquisition of non-guidance and payment for consultancy and for which the assessee had ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for deleting the disallowance of expenditure incurred on training of the employees. Additions Made u/s 92CA(3) - Whether the CIT(A) had erred in deleting the addition made by the A.O. on account of TPO-1's order u/s 92 CA(3) dated 21.02.2005 on account of adjustments in the ALP of international transactions of the assessee – Held that:- Sec. 92C(1) referred to ALP in relation to an international transaction - Rule 10B(1)(e) read with section 92C deals with TNMM, and it refers to only net profit margin realized by an enterprise from an international transaction or a class of such transaction, but not operational margins of enterprises a whole. The net margins on the transaction was the basis of comparison - Only in cases where profits of an enterprise were attributable to similar transactions and when an enterprise does not have any other transaction or activity which was not similar, and which distorts the profits, then probably the net margin derived by an enterprise may also be the net margin of a transaction - In other words, when in an enterprise, only similar transactions were undertaken, i.e., all the transactions were of the same type, same class and of similar variet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are heard together and are being disposed of by way of this common order. 2. Facts in brief - The assessee is a public limited company and is promoted by Denso Corporation, Japan (Denso Japan). Denso Japan holds 47.93% equity in the assessee company and the overall management and controls rests with Denso Japan. Sumitomo Corporation, which is primarily a trading company, holds only 10.27% equity in the assessee company. For the year under assessment, the assessee filed its income tax return on October 30, 2002 declaring total income of Rs. 19,44,45,442/-. The return was originally processed under sec. 143(1) of the Income-tax Act, 1961 (the Act) vide intimation dated February 25, 2003 and thereafter was taken up for scrutiny by issue of a notice under section 143(2) dated October 22, 2003. The Ld. Additional Commissioner of Income Tax, Range 10, New Delhi (AO) was pleased to complete the assessment under section 143(3) of the Act vide her order dated March 30, 2005 on a total income of Rs. 27,17,76,470/-. 3. The Assessing Officer made certain additions and disallowances as well as adjustment under the Transfer Pricing Provisions. First Appellate Authority deleted the same. Aggr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to manufacture and sale products by using technology and patents of the Japan Foreign company. Right to manufacture allowed in the agreement entered into by the assessee with Denso Corporation, had nexus with receipt of technical information. Payment of Royalty during the current year is made on the basis of the same agreement that was considered by the Delhi Bench of the Tribunal in the case of the assessee for the A.Y. 2001-02. The Tribunal vide its order dated 20th March, 2008 in ITA No. 4798/Del/2004, has held as under:- "7. With regard to ground taken by the revenue for deleting the addition of Rs. 3.29 crores on account of royalty paid. The issue is squarely covered in favour of the assessee by the order of ITAT in assessee's own case for assessment years 1988-89 to 1997-98. During the year under consideration also, the CIT(A) has rightly deleted the addition after recording finding with reference to the terms of the agreement which were similar to the terms of agreement during the course of earlier years. The Tribunal has deleted the disallowance. Following are the findings of the Tribunal in assessee's own case: "A perusal of the above case law will show that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iew of the above ratio of Hon'ble Supreme Court the amount claimed by the assessee becomes less than 7% and the amount will be allowable. Apart from it the payment as noted by Their Lordships in the case of Tata Robins Frazer Ltd. v. CIT (supra) the amount comes from the circulation of the capital and not from any capital asset. Further we may refer the decision of the Apex Court in the case of Gotan Lime Syndicate v. CIT[1966] 59 ITR 718 in which it was also laid down that the amount of royalty has to be allowed as revenue expenditure, as the said expenditure was in relation with the excavation of raw material. More you take the more royalty you pay. This ratio is again applicable in the case as amount of royalty in the case is directly linked with the volume of contract products. The more assets will produce, the amount of royalty will increase. In case assessee stops manufacturing of contract products the amount of royalty will not be payable. In view of the above ratio the amount of royalty which is linked with the volume of production is allowable as revenue expenditure. On the basis of above discussion the cumulative result is that amount of royalty being paid w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d for its new proposed activity, namely, for the manufacture of trucks, it set up a new factory after obtaining know how from its German collaborators, which collaboration was being considered by the High Court. In principle, it would seem to make no difference between a case where an existing company undertakes a totally new line of activity for which it has to establish a new factory, and a case where for manufacturing a new product a new company is constituted or formed. What we have to consider is whether the payment has been made for acquiring an asset of an enduring nature, if know-how has been acquired unrelated to secret or patented processes or the right to use the trade name or trade mark, then the acquirer of that know-how - since that phrase was repeatedly used or emphasized - would seem to acquire no asset of an enduring nature. If the know-how acquired relates to the setting up of the plant or machinery, then perhaps it decide that question in the present reference. If the know-how acquired relates to the process of manufacturing, then the payment made for the same would have to be considered as revenue expenditure, since the acquirer does not obtain by the expenditur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Rather it assisted in manufacturing the products as required. For this purpose whether the company is newly set up or an existing one will not make any difference. The answer is also available in the decision rendered by Hon'ble Bombay High Court in the case of Gannon Norton Metal Diamond Dies Ltd. (supra). The Hon'ble High Court held that if the know-how acquired relates to the process of manufacturing, then the payment made for the sale would have to be considered as revenue expenditure since the acquirer does not obtain any asset of an enduring nature. The Hon'ble Supreme Court in the case of Empire Jute Co. Ltd., 124 ITR 1 = (2002-TIOL-238-SC-IT) held that in a case where expenditure even if incurred for obtaining an advantage of enduring benefit, may, none the less, be on revenue account and the test of enduring benefit may break down. It is not every advantage of enduring nature acquired by an assessee that brings the case within the principle laid down in this test. What is material to consider is the nature of the advantage in a commercial sense and it is only where the advantage is in the capital field that the expenditure would be held as capital expenditure. If the adv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eement was not available. (iii) In the agreement entered into between the two companies, specific charges that were to be charged for this service were not mentioned. He held that the assessee company was not liable to make payments to Denso Haryana Pvt. Ltd. towards sharing of communication network called "NICE-NET" (Nippon Denso Integrated Communication Earth Network). The first appellate authority brought out the arguments of the assessee in Para 10.33 which read as under:- "10.3.3 The appellant in its submission stated that they entered into the agreement with Denso Haryana Pvt Limited for using the NICE - NET network on cost sharing basis for reporting and communication recharged to Denso Group Companies world over. Further, the said expenses were paid to Denso Haryana Pvt Limited, who has shown the said receipts as income during the year under consideration. It is further submitted that Denso Haryana Pvt Ltd. has been assessed under the same jurisdiction. Further, there is no dispute that the services were rendered and actually used by the appellant company during the year under consideration. The AO erred in concluding that the appellant had not obtained RBI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... during the year under consideration. The net work was being used by Denso group companies in India and cost incurred was shared. We are unable to uphold the finding of the AO that the expenditure in question cannot be allowed, as the cost sharing agreement is a sham agreement. When costs are being shared, we do not understand as to how specific charges or quantification of charges are asked to be mentioned in the agreement. Non-mentioning of the same in the agreement cannot be a ground for disallowance. No R.B.L approval was required or payments were made in India. The Assessing Officers of Denso Haryana Pvt. Ltd. and the assessee are the same. When Denso Haryana Pvt. Ltd. made a payment of Rs. 10,41,434/- to a foreign company, the AO has not doubted that expenditure. When Denso Haryana Pvt. Ltd. is recovering a part of the expenditure from the assessee, cost reduction is accepted but the expenditure is doubted in the hands of the assessee. When an understanding is arrived at between different entities, the A.O. cannot sit in judgment as to the date of implementation etc. On these facts, we are of the opinion that the disallowance is made based on conjectures and surmises. Thus, w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only up to assessment year 1998-99. The CIT(A) has accepted the assessee's contention and allowed the depreciation u/s 32(1) at Rs. 3.08 crores as know how fee paid by treating the same as intangible assets. This verdict of the CIT(A) was accepted by the assessee and no appeal was filed before the Tribunal. 9. With regard to the amount of Rs. 63.46 lakhs the assessee claimed it as revenue expenditure which was disallowed by the Assessing Officer on the plea that it was capital in nature. By the impugned order, the CIT(A) confirmed the action of the Assessing Officer and allowed only depreciation thereof u/s 32(1) which was also accepted. The assessee preferred an appeal before ITAT and the ITAT had allowed the assessee's appeal and allowed the said amount in full as revenue expenditure in ITA. No. 4714/Del/2004. Thus to the extent, the ground taken by the revenue is misconceived. So far as the amount of Rs. 63.46 lakhs is concerned, the same is covered by the order of ITAT in assessee's own case, respectfully following the same to this extent, we do not find any reason to interfere in the order of CIT(A)." 16. The first appellate authority followed the order of the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m SCJ. 7. On the facts and circumstances of the case and in law, the order of the CIT(A) has erred in deleting the addition of Rs. 4,19,33,498/- made by the AO on account of royalty expenses treating the same as capital expenditure in nature. 8. On the facts and circumstances of the case and in law, the order of the CIT(A) has erred in deleting the addition of Rs. 62,10,292/- made by the AO on account of payment of knowhow fees treating the same capital in nature. 9. On the facts and circumstances of the case and in law, the order of the CIT(A) has erred in deleting the addition of Rs. 13,13,332/- made by the AO on account of NECNET charges paid to Denso Haryana for use of the internet. 10. On the facts and circumstances of the case and in law, the order of the CIT(A) has erred in deleting the addition of Rs. 1,00,02,674/- paid to Denso Corporation, Japan, for technical services training treating the same as revenue expenditure in spite of capital expenditure treated by the AO. 11. On the facts and circumstances of the case and in law, the order of the CIT(A) has erred in deleting the addition of Rs. 64,19,573/- made by the AO on account of dedu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terial, components etc. TNMM 4,906,400 5. Payment for technical know-how TNMM 3,780,796 6. Payment of testing fees TNMM 682,08 4. Method used by assessee to determine the Arm's length price (ALP) The assessee has relied upon the entity-wise Transactional Net Margin Method (TNMM) using margin over the total cost as the Profit Level Indicator (PLI) as the most appropriate method to establish that the international transactions entered into by it are at arm's length. The tested party is the assessee itself, i.e., assessee's net profit margin over the cost has been compared with the margin of other comparable companies in India engaged in similar function. 4.1 During the year, assessee has imported raw materials amounting to Rs. 49,86,69,729/- from Sumitomo Corporation, Japan (SCJ) out of the total import of Rs. 57,77,00,221/-. It means that purchases from SCJ constituted approximately 86.3% of the total imports and 37.5% of total raw material consumed. It was submitted during the course of proceedings that SCJ is a trading company and does not manufacture any of the items supplied to the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... MM shall not provide the most reliable measure of the arm's length price in relation to this international transaction. He, therefore, rejected TNMM as the most appropriate method. The TPO concluded that (a) the assessee failed to discharge its responsibility as the method relied upon by it is not the most appropriate method; (b) it has failed to give reasonable data i.e. cost of purchase in the hands of SCJ to determine the ALP by Retail Price Method (RPM); (c) it clearly emerges that no method other than the CUP can be applied in this case to determine the ALP of the import of the components from SCJ. 23. As the assessee has not brought out any difference between the quality of components purchased from the A.E. and quality of components purchased from uncontrolled domestic suppliers, the TPO held that the ALP of imports from A.E. could be determined by comparing it with the prices of uncontrolled domestic suppliers. 24. In case of certain components the indigenization took place in the subsequent years the TPO held that the prices of these goods in the subsequent years were to be taken and used as comparables. 25. The TPO while using CUP method compared the prices of four ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lable for only 4 types of components; (b) there are significant differences between the characteristics of the transaction of import of raw material and components from Sumitomo Japan and the characteristics of the transaction of procurement of raw material and components from local Indian vendors; and (c) there is absence of a suitable manner/methodology to adjust for such differences; I am of the considered view that the CUP method is not an appropriate method for determining the arm's length nature of the appellant's international transactions of import of raw material and components from Sumitomo Japan." Thereafter he determined the arm's length price by adopting operating profits by sales as a profit level indicator and after making comparison with 13 companies held that the appellant's international transactions with A.E. are at arm's length. He held that TNMM is to be used as most appropriate method. 28. Aggrieved the Revenue is in appeal on the following grounds:- "1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs. 1,36,31,665/- made by the A.O. on account of TPO-1's order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rry out the function relating to manufacture and sale of automotive components. He submitted that the assessee was a full fledged risk bearing automotive component manufacturer which depended on it's AEs for technical expertise and know-how required to carry out its business. The assessee submitted that the Transactional Net Margin Method is the most appropriate method as explained by the CIT(A) in his order. He argued that for the purpose of bench marking the transactions of the assessee cannot be analyzed on a transaction-by-transaction basis as all the transactions were incidental and ancillary to the main operation of manufacture of automotive components. He supported bench marking of international transactions at the entity level by adopting operating profit/total cost (OP/TC) as the relevant profit level indicator. 31. He further submitted that no external or internal Comparable Uncontrolled Price (CUP) was available to the assessee for benchmarking on a stand-alone basis. The reasons given for not adopting CUP method are (a) reliable information on external CUPs could not be obtained; (b) ALP per unit price of uncontrolled enterprises is substantially dependent upon factor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re transactional level net margin approach under TNMM has been upheld. The cases are Benetton India (P.) Ltd. v. ITO[2012] 134 ITD 229; UCB India (P.) Ltd. v. Asstt. CIT[2009] 30 SOT 95/121 ITD 131 (Mum.), Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT[2011] 44 SOT 391. He submitted that in each of these cases, there are separate business segments/activities available, to carry out a net margin computation of the respective segments. 34. The sum and substance of the assessee's submissions is that, in its case the import of raw material, import of capital goods, payment of royalty, payment of know-how fees, payment of short stay expenses and testing fees as well as procurements of raw-material domestically are transactions which are inextricably integrated and that separate results for each transaction cannot be computed and hence entity level profit level Indicator (PLI) is to be taken for the purpose of bench marking and that such methodology is permitted under TNMM. In support of his contention, he relied on AS-17 i.e. Segment Report as well as Para 3.10 of OECD Guidelines. 35. The second limb of the argument is that the valuation of the goods has been accepted by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed enterprise on similar operations. Under this method, the net profit margin realized by an AE from an international transaction computed in relation to a particular factor such as costs incurred, sales, assets utilized, etc. The net profit margin realized by an AE is compared with net profit margin of the uncontrolled transactions arrive at the ALP. The TNMM is similar to RPM and CPM to the extent that it involves comparison margin earned in a controlled situation with margins earned from comparable uncontrolled situation. The only difference is that, in the RPM and CPM methods, comparison is of margins of gross profit and whereas in TNMM the comparison is on margins of net profit. TNMM requires comparison between net margins derived from the operations of the uncontrolled parties and net margins derived by an AE from similar operations. Net margin is indicated by the rate of return on sales or cost of operating assets, and this forms the basis for TNMM. A functional analysis of the tested party or the independent enterprise, as the case may be, is required to determine whether the transactions are comparable and the adjustments that are required to be made to obtai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e principles of Chapter I). Thus, a TNMM operates in a manner similar to the cost plus and resale price methods. This similarity means that in order to be applied reliably, the transactional net margin method must be applied in a manner consistent with the manner in which the resale price or cost plus method is applied. This means in particular that the net margin of the taxpayer from the controlled transaction (or transactions that are appropriate to aggregate under the principles of Chapter I) should ideally be established by reference to the net margin that the same taxpayer earns in comparable uncontrolled transactions. Where this is not possible, the net margin that would have been earned in comparable transactions by an independent enterprise may serve as a guide. A functional analysis of the associated enterprise and, in the latter case, the independent enterprise is required to determine whether the transactions are comparable and what adjustments may be necessary to obtain reliable results. Further, the other requirements for comparability, and in particular those of paras 3.34 to 3.40, must be applied." 71. Para 3.42 of TP Guidelines for Multinational Enterprises a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . From a perusal of this para it is clear that they are applicable all methods, that may be adopted for arriving at the ALP. The learned counsel for the assessee cannot restrict para 1.20 to the method of transactional net margin. Thus, this argument cannot be accepted. Coming to the decision relied upon by the assessee in the case of Philips Software Centre (P) Ltd. v. Asstt. CIT[2008] 119 TTJ (Bang) 721: [2008] 15 DTR (Bang)(Trib) 505 : [2008] 26 SOT 2 (Bang) = (2008-TII-09-ITAT-BANG-TP), the Bangalore Bench of the Tribunal was considering a case wherein the assessee's business was only software development. So the comparable of another assessee also only in software development was considered sufficient. This was a case of aggregation of similar transactions and where the assessee had no other transactions. In our case, 50 per cent of the assessee's production is from APIs imported from the AE and whereas the balance is production from APIs which are not imported from AE. There is also trading activity. Thus, we are unable to accept the contentions of Shri Rajan Vora. 71B. We are surprised that the assessee does not want to come out with information or documentation to de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sactions are undertaken, i.e., all the transactions are of the same type, same class and of similar variety, and the enterprise does not have any other transaction which is not similar, in such a situation, the operating margins of the enterprise would be the TNMM of a class of transaction." The aggregation contemplated in the Act is of the class of international transaction only. 37. Coming to the contention of the assessee that the Tribunal cannot go into this issue as the AO as well as the CIT(A) had accepted entity level operating margin for the purpose of bench marking, we observe that the entire issue in this case is whether the most appropriate method is TNMM method or CUP method. The AO applied CUP method and rejected the TNMM method adopted by the assessee. The Assessing Officer gave reasons for rejecting the TNMM which are extracted in para 22 of this order. The issue whether the assessee has correctly applied TNMM method or not was the subject matter of discussion and for the reason given the method itself was rejected. In any event when the assessee wrongly applies provisions of the Act and Rules, the Tribunal has power to point out the mistake. If the Assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... done away with hierarchical approach in selecting the method for determination of arm's length price. The OECD has abandoned its earlier position that transactional profit methods may be used "to approximate arm's length conditions when traditional transactional methods cannot be reliably applied alone, or exceptionally cannot be applied at all". In sharp contrast to the said observation, 2010 OECD Guidelines, in paragraph 2.4, recognize that "there are situations when transactional profit methods are found to be more suitable (vis-a-vis traditional transactional methods)" such as, in a situation, "where each of the party makes a unique contribution in relation to controlled transaction, or where the parties engage in highly integrated activities ". This change in OECD approach is quite in line with Indian transfer pricing legislation which requires selection of most appropriate method rather than the method being picked up in the order of priority. To this extent, the approach of OECD and Indian transfer pricing legislation is now quite in harmony with each other. 63. It will, however, be stretching the things too far to suggest that in the 2010 version of OECD Guidelines, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... proceed without any such priority order, the fact remains that as long as CUP method can be reasonably applied in determining the arm's length price of an international transaction in a particular fact situation, and unless another method is proven to be more reliable a method vis-a-vis the fact situation of that particular case, the CUP method is to be preferred. The reason is simple. When associated enterprises enter into a transaction at such conditions in commercial and financial terms, which are different from commercial and financial terms imposed in comparable transaction between independent enterprises, the differences in these two sets of conditions in financial and commercial terms are attributed to inter relationship between the associated enterprises, and it is this impact of interrelationship between the associated enterprises that is sought to be neutralized by the transfer pricing regulations. As long as CUP method can be reliably applied on the facts of a case, it does offer most direct method of neutralizing the impact of interrelationship between AEs on the price at which the transactions have been entered into by such AEs. 65. While traditional methods se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficacy, of determining the ALP. 67. The most fundamental aspect, therefore, that we must address ourselves to is whether CUP method of determining the arm's length price can be reasonably applied in the fact situation that we are in seisin of." 39. As there is a high degree of product comparability, in our considered opinion CUP method is the most appropriate method to be followed in the case on hand. The finding of the learned CIT(A) on this issue does not convince us. If there are significant difference in the facts and circumstances between the transactions of import of raw-material and components from Japan vis-a-vis procurement of raw-material and components from local Indian vendors, suitable adjustments can be made for the same. The method itself cannot be rejected. Hence, this issue is decided in favour of the Revenue. 40. Next issue is whether future data can be taken for the purpose of comparables. On this issue we uphold the order of the Commissioner of Income-tax (Appeals) that the Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking. Hence in respect of 7 components, the TPO's action in using futur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re is no other transaction of sale to any outsider and also there is no other international transaction. Where there are unrelated international transactions, it is wrong to apply TNMM at an entity level. Further, even assuming that in applying the TNMM on entity level for the transaction of import of raw material the overall net profit is better than other comparables, an adjustment can still be made by subjecting the AMP expenses to the TP provisions. There is no bar on the power of the TPO in processing all international transactions under the TP provisions even when the overall net profit earned by the assessee is better than others. Earning an overall higher profit rate in" comparison with other comparable cases cannot be considered as a licence to the assessee to record other expenses in international transactions without considering the benefit, service or facility out of such expenses at arm's length. All the transactions are to be separately viewed. Also, the contention fails if any of the other methods (CUP etc) are adopted instead of TNMM" (See Paras 21.3 to 21.8 of the special bench order). 42.2 This being a binding precedent as well as the correct position of law on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (ii) Import of capital goods; (iii) Export of finished goods (samples); (iv) Payment of royalty; (v) Payment of application cost and technical assistance fee; (vi) Purchase of software as well as reimbursement of expenses. 48. The assessee applied TNMM method taking entity level profit for the purpose of bench marking. The TPO applied the CUP method. The first appellate authority held in favour of the assessee. Aggrieved, the Revenue is in appeal. For the reasons given while disposing of the issue for the A.Y. 2002-03, we uphold the findings of the TPO that CUP method is the most appropriate method to be applied in this case subject to making suitable adjustments due to various factors. 49. Coming to the issue of comparables there are two issues - the first being sales and second being turnover filter. As we have approved CUP method, any discussion on this filter is of no consequence. 50. Use of single year data of comparable companies is also legally correct though it does not have any affect on the ALP. 51. We also approve the CIT(A)'s finding that foreign exchange gain or loss, is operating in nature and hence adjustment for the same ..... X X X X Extracts X X X X X X X X Extracts X X X X
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