https://www.taxtmi.com/caselaws?id=774045 Transfer-pricing computation may require reasonably accurate capacity-utilisation and customs-duty adjustments where material differences affect manufacturing profitability. A full-fledged entrepreneur's low utilisation, including during recession, can justify a capacity adjustment; reduced sales to associated enterprises alone do not negate it. Foreign-exchange losses enter operating margins only when actually incurred, not when they arise from notional restatement. Software-product companies should be excluded from comparables for a pure software-development service provider, while functionally comparable entities meeting applied filters should be included. Obsolete-stock provisions are not deductible until stock is sold, whereas software applications qualify for 60% depreciation. Reimbursement of seconded employees' salary costs without an income element does not require separate withholding where salary tax has been deducted. en-us Fri, 06 Jun 2025 00:00:00 +0530 Tue, 25 Aug 2026 11:36:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774045 Transfer-pricing computation may require reasonably accurate capacity-utilisation and customs-duty adjustments where material differences affect manufacturing profitability. A full-fledged entrepreneur's low utilisation, including during recession, can justify a capacity adjustment; reduced sales to associated enterprises alone do not negate it. Foreign-exchange losses enter operating margins only when actually incurred, not when they arise from notional restatement. Software-product companies should be excluded from comparables for a pure software-development service provider, while functionally comparable entities meeting applied filters should be included. Obsolete-stock provisions are not deductible until stock is sold, whereas software applications qualify for 60% depreciation. Reimbursement of seconded employees' salary costs without an income element does not require separate withholding where salary tax has been deducted. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774045