Topic

Foreign Exchange Gains

2 articlesLatest June 2026
Transfer Pricing | Foreign Exchange Gains Classified as Operating Income Under TNMM, Expense Allocation Tied to Gross Profit Margins: ITAT Delhi
Case Law Analysis
|Income Tax Appellate Tribunal

Transfer Pricing | Foreign Exchange Gains Classified as Operating Income Under TNMM, Expense Allocation Tied to Gross Profit Margins: ITAT Delhi

ITAT Delhi has ruled that foreign exchange gains arising from international transactions must be treated as operating income for transfer pricing purposes, and expense allocation must be calibrated using gross profit margins to determine the arm's length price. This sets a critical precedent for multinational enterprises using TNMM, forcing a reevaluation of how forex volatility and cost allocation impact their TP documentation and compliance strategy.

Section 80G | CSR Donations Eligible for Tax Deduction If Recipient Is Registered Charity : ITAT Delhi
Case Law Analysis
|Income Tax Appellate Tribunal

Section 80G | CSR Donations Eligible for Tax Deduction If Recipient Is Registered Charity : ITAT Delhi

The ITAT Delhi has ruled that corporate social responsibility (CSR) expenditures under the Companies Act, 2013 qualify for income tax deduction under Section 80G, provided the recipient institution is duly registered under the Income Tax Act. This clarifies a long-standing ambiguity for businesses and aligns CSR compliance with tax incentives, impacting thousands of corporate donors nationwide.

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