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)