S. 92C : Transfer pricing – Arm’s length price – Comparables —Company which is a giant risk taking company and engaged in development and sale of  software products  is not Comparable —Foreign exchange fluctuation gain or loss is  to be considered for transfer pricing analysis  if it is in respect of current year’s turnover .  
				
					Tribunal held that  Company which is a giant risk taking company and engaged in development and sale of  software products  is not Comparable —Foreign exchange fluctuation gain or loss is  to be considered for transfer pricing analysis  if it is in respect of current year’s turnover . ( AY.2012-13)