https://www.taxtmi.com/caselaws?id=186080 Transfer pricing adjustment on the assessee's international transactions was held unsustainable because the assessee and its parent operated as independent service providers, and business volumes depended on work secured by the parent. The Tribunal accepted that lower margins resulted from fluctuating revenues, fixed costs, idle capacity, and under-absorption of manpower and infrastructure costs. It also accepted the exclusion of idle fixed expenses in the margin computation and found that the operating margin remained within the permissible range against the arithmetical mean of comparables. The addition was therefore deleted and the transactions were treated as at arm's length. en-us Thu, 30 Apr 2015 00:00:00 +0530 Wed, 07 Sep 2016 10:22:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186080 Transfer pricing adjustment on the assessee's international transactions was held unsustainable because the assessee and its parent operated as independent service providers, and business volumes depended on work secured by the parent. The Tribunal accepted that lower margins resulted from fluctuating revenues, fixed costs, idle capacity, and under-absorption of manpower and infrastructure costs. It also accepted the exclusion of idle fixed expenses in the margin computation and found that the operating margin remained within the permissible range against the arithmetical mean of comparables. The addition was therefore deleted and the transactions were treated as at arm's length. Case-Laws Income Tax Thu, 30 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186080