https://www.taxtmi.com/caselaws?id=362762 The High Court upheld the Tribunal's decision in a Transfer Pricing case, ruling against the Assessee's claims for adjustments due to under-utilization of rated capacity and working capital. The Court agreed with the Tribunal that depreciation need not be directly proportional to capacity utilization and that the Assessee failed to establish a linear relationship between depreciation cost and machine utilization. The Court emphasized the Tribunal's findings were based on relevant material and dismissed the appeal, stating that mere dissatisfaction with factual findings does not warrant invoking the Income Tax Act. The appeal was dismissed with no order as to costs. en-us Tue, 26 Jun 2018 00:00:00 +0530 Mon, 01 Oct 2018 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362762 The High Court upheld the Tribunal's decision in a Transfer Pricing case, ruling against the Assessee's claims for adjustments due to under-utilization of rated capacity and working capital. The Court agreed with the Tribunal that depreciation need not be directly proportional to capacity utilization and that the Assessee failed to establish a linear relationship between depreciation cost and machine utilization. The Court emphasized the Tribunal's findings were based on relevant material and dismissed the appeal, stating that mere dissatisfaction with factual findings does not warrant invoking the Income Tax Act. The appeal was dismissed with no order as to costs. Case-Laws Income Tax Tue, 26 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362762