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| The Tax Publishers2019 TaxPub(DT) 7914 (SC) : (2019) 267 TAXMAN 0386 INCOME TAX ACT, 1961
Section 261 Section 92C
Where the Department preferred SLPs to appeal against the judgment of Karnataka High Court in CIT v. Yodlee Infotech (P.) Ltd. [ITA No. 174 of 2015, dt. 25-7-2018] : 2019 TaxPub(DT) 7950 (Karn-HC), whereby the High Court held that it is settled that forex gain/loss would be included while working out operating margin of assessee-company in TP analysis. Therefore, the Tribunal was justified in directing the AO to include forex gain/loss while arriving at PLI of the assessee, the Supreme Court dismissed the SLPs.
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Department preferred SLP to appeal against the judgment of Karnataka High Court in CIT v. Yodlee Infotech (P.) Ltd. [ITA No. 174 of 2015, dt. 25-7-2018] : 2019 TaxPub(DT) 7950 (Karn-HC), whereby the High Court held that it is settled that forex gain/loss would be included while working out operating margin of assessee-company in TP analysis. Therefore, the Tribunal was justified in directing the AO to include forex gain/loss while arriving at PLI of the assessee.Held: In view of the Circular, dated 8-8-2019 issued by the CBDT, the tax effect being less than two crores, the court found no reason to interfere. The special leave petitions were dismissed. The Supreme Court dismissed the SLPs.
REFERRED :
FAVOUR : SLPs dismissed.
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