https://www.taxtmi.com/caselaws?id=428916 The appeal was allowed for statistical purposes, with all major issues remitted back to the Transfer Pricing Officer (TPO)/Assessing Officer (AO) for fresh consideration. The Tribunal directed adjustments for extraordinary expenses, foreign exchange fluctuations, customs duty, and underutilization of capacity, emphasizing the need to accurately reflect operating margins. Additionally, re-computation of operating margins was ordered following a Mutual Agreement Procedure (MAP) resolution with Japan. en-us Wed, 30 Mar 2022 00:00:00 +0530 Thu, 13 Oct 2022 08:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428916 The appeal was allowed for statistical purposes, with all major issues remitted back to the Transfer Pricing Officer (TPO)/Assessing Officer (AO) for fresh consideration. The Tribunal directed adjustments for extraordinary expenses, foreign exchange fluctuations, customs duty, and underutilization of capacity, emphasizing the need to accurately reflect operating margins. Additionally, re-computation of operating margins was ordered following a Mutual Agreement Procedure (MAP) resolution with Japan. Case-Laws Income Tax Wed, 30 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428916