https://www.taxtmi.com/caselaws?id=433564 The Tribunal partly allowed the appeal, upholding the Transfer Pricing Officer's adjustments to the arm's length price and rejecting certain comparable companies while allowing others. It affirmed the treatment of foreign exchange fluctuation as operating, directed reevaluation of working capital adjustments, denied capacity utilization adjustment, rejected the use of multiple-year data, and remanded the disallowance of expenses for further scrutiny. The Tribunal also ruled in favor of the assessee regarding the claim of depreciation on UPS. Overall, the Tribunal provided specific directions for re-examination and adjustments on various grounds. en-us Fri, 04 Nov 2022 00:00:00 +0530 Wed, 01 Feb 2023 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433564 The Tribunal partly allowed the appeal, upholding the Transfer Pricing Officer's adjustments to the arm's length price and rejecting certain comparable companies while allowing others. It affirmed the treatment of foreign exchange fluctuation as operating, directed reevaluation of working capital adjustments, denied capacity utilization adjustment, rejected the use of multiple-year data, and remanded the disallowance of expenses for further scrutiny. The Tribunal also ruled in favor of the assessee regarding the claim of depreciation on UPS. Overall, the Tribunal provided specific directions for re-examination and adjustments on various grounds. Case-Laws Income Tax Fri, 04 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433564