https://www.taxtmi.com/caselaws?id=271677 The Tribunal partly allowed the appeal, remitting the matter to the AO for fresh adjudication on restricting the ALP adjustment to the overall income earned by the AE from third parties. The Tribunal upheld the TPO's rejection of the internal TNMM and denial of adjustment for underutilization of capacity. The grievance regarding the selection of comparables was deemed academic and did not require adjudication. en-us Wed, 03 Feb 2016 00:00:00 +0530 Sat, 30 Apr 2016 10:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271677 The Tribunal partly allowed the appeal, remitting the matter to the AO for fresh adjudication on restricting the ALP adjustment to the overall income earned by the AE from third parties. The Tribunal upheld the TPO's rejection of the internal TNMM and denial of adjustment for underutilization of capacity. The grievance regarding the selection of comparables was deemed academic and did not require adjudication. Case-Laws Income Tax Wed, 03 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271677