https://www.taxtmi.com/caselaws?id=302167 The appeal filed by the assessee regarding transfer pricing adjustments for finished goods exported to Associated Enterprises was partially allowed. The adjustment related to transfer pricing was confirmed, but the capacity utilization adjustment issue was remanded back to the tax authorities for re-examination in accordance with relevant legal principles. The decision emphasized that adjustments for capacity utilization differences should be made in the profit margins of comparables, not the assessee, following precedents and rules under the Income-tax Regulations. en-us Fri, 15 Feb 2019 00:00:00 +0530 Sat, 07 May 2022 20:38:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302167 The appeal filed by the assessee regarding transfer pricing adjustments for finished goods exported to Associated Enterprises was partially allowed. The adjustment related to transfer pricing was confirmed, but the capacity utilization adjustment issue was remanded back to the tax authorities for re-examination in accordance with relevant legal principles. The decision emphasized that adjustments for capacity utilization differences should be made in the profit margins of comparables, not the assessee, following precedents and rules under the Income-tax Regulations. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302167