https://www.taxtmi.com/caselaws?id=439897 The Tribunal partly allowed the appeal, directing re-computation and adjustments based on specific findings. The assessee's challenges to transfer pricing adjustments, capacity utilization, and extraordinary expenses were partially upheld. The Tribunal directed the AO/TPO to follow DRP's directions on tolling expenses and fixed vs. variable costs. Errors in computing margins for comparable companies were noted, requiring re-computation. The Tribunal restricted transfer pricing adjustments to international transactions only. The disallowance of gratuity fund contribution was overturned, citing relevant case law. Other general issues and penalty proceedings did not require specific adjudication. en-us Fri, 30 Jun 2023 00:00:00 +0530 Tue, 04 Jul 2023 09:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439897 The Tribunal partly allowed the appeal, directing re-computation and adjustments based on specific findings. The assessee's challenges to transfer pricing adjustments, capacity utilization, and extraordinary expenses were partially upheld. The Tribunal directed the AO/TPO to follow DRP's directions on tolling expenses and fixed vs. variable costs. Errors in computing margins for comparable companies were noted, requiring re-computation. The Tribunal restricted transfer pricing adjustments to international transactions only. The disallowance of gratuity fund contribution was overturned, citing relevant case law. Other general issues and penalty proceedings did not require specific adjudication. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439897