| COURT: | ITAT Bangalore |
| CORAM: | Abraham P. George (AM), P. Madhavi Devi (JM) |
| SECTION(S): | 9(1)(vii), 92CA(3) |
| GENRE: | International Tax, Transfer Pricing |
| CATCH WORDS: | operational income, Secondment agreement |
| COUNSEL: | Rajan Vora |
| DATE: | October 17, 2014 (Date of pronouncement) |
| DATE: | October 20, 2014 (Date of publication) |
| AY: | 2009-10 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Foreign exchange fluctuation gain arising on realization of trade debtor’s, payment to creditors etc is operational income. Tests for distinguishing secondment contract with technical services agreement | |
(i) The TPO had considered foreign exchange fluctuation gains to be non-operational in nature. This view was confirmed by the DRP stating that the foreign exchange fluctuations had nothing to do with the business operations of a tax payer. The …
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