https://www.taxtmi.com/caselaws?id=271899 The ITAT Delhi dismissed the assessee's claim for capacity adjustment in transfer pricing, finding no reliable data to support differing capacity utilization between the assessee and comparables. Several companies were excluded from the comparable set due to functional dissimilarity or mixed revenue streams from software products and services, which distorted profit margins. Companies providing predominantly software development services with available segmental data were retained as comparables. One company was excluded due to its international transaction structure under section 92B(2). The tribunal upheld the impugned order except for Zylog Systems Ltd., directing AO/TPO to reconsider its inclusion after hearing the assessee's objections. Overall, the appeal was largely dismissed, affirming the transfer pricing adjustments and the selection of comparables as per the original order. en-us Fri, 05 Feb 2016 00:00:00 +0530 Tue, 05 May 2026 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271899 The ITAT Delhi dismissed the assessee's claim for capacity adjustment in transfer pricing, finding no reliable data to support differing capacity utilization between the assessee and comparables. Several companies were excluded from the comparable set due to functional dissimilarity or mixed revenue streams from software products and services, which distorted profit margins. Companies providing predominantly software development services with available segmental data were retained as comparables. One company was excluded due to its international transaction structure under section 92B(2). The tribunal upheld the impugned order except for Zylog Systems Ltd., directing AO/TPO to reconsider its inclusion after hearing the assessee's objections. Overall, the appeal was largely dismissed, affirming the transfer pricing adjustments and the selection of comparables as per the original order. Case-Laws Income Tax Fri, 05 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271899