Tribunal held that the foreign exchange loss on account of exchange rate fluctuations arose in the normal course of business transaction. Therefore, while computing the margin for determining the arm’s length price, the foreign exchange loss had to be taken as part of the operating margin.( AY.2010-11)
Vitech Systems Asia Pvt. Ltd. v. ITO (2020) 81 ITR 58 (SN) (Hyd) (Trib)
S.92C: Transfer pricing -Arm’s length price — Exchange rate fluctuations —Taken part of operating margin [ S.92CA ]