Tribunal held that Company having huge brand value and extraordinary events of to be excluded.-Computation of working capital level and consequent adjustment on account of working capital remanded to Transfer Pricing Officer for fresh consideration. Gains arising from fluctuation of foreign exchange having nexus with international transactions to be treated as operating income and taken into consideration. ( AY.2012-13)
Fidelity Business Services India Pvt. Ltd. v. ACIT (2021) 85 ITR 14 (SN)(Bang) (Trib)
S. 92C : Transfer pricing – Arm’s length price Comparables — Company having huge brand value and extraordinary events of to be excluded.-Computation of working capital level and consequent adjustment on account of working capital remanded to Transfer Pricing Officer for fresh consideration- Gains arising from fluctuation of foreign exchange having nexus with international transactions — to be treated as operating income and taken into consideration.