Tribunal held that  only the international transactions which call for transfer pricing adjustment and not the entity level transactions of the assessee. Tribunal also held that  the foreign exchange gain or loss earned or incurred by the assessee and the other comparables had to be considered as a part of operating revenue or cost not only for the reason that the assessment year under consideration was prior to the applicability of the safe harbour rules but also that there could be no question of applying rule 10TA(k) in the absence of the assessee having or exercising option to be subjected to the safe harbour rules. Once it was proved that the foreign exchange gain emanated from the regular business transactions of the assessee with its associated enterprises, it had to be taken as an item of operating revenue.( AY.2012-13)