Sec. 92C of Income-tax Act, 1961 & Rule 10B(1)(e) of Income-tax Rules, 1962— Transfer pricing - Foreign exchange fluctuation in relation to trading transactions, prior to Safe Harbour Rules from 2013, should be treated as an operating item. Thus, the amount of foreign gain/loss arising out of the revenue transactions should be considered as an item of operating revenue/cost, both for the assessee as well as the comparables. - VISHAY COMPONENTS INDIA (P.) LTD. V/s ASSTT. CIT - [2020] 204 TTJ 649 (ITAT-PUNE)