https://www.taxtmi.com/caselaws?id=774045 ITAT Chennai ruled in favor of the assessee on multiple transfer pricing and tax issues. The tribunal held that reduced sales to associated enterprises cannot justify rejecting idle capacity adjustments, particularly during global recession when the assessee's capacity utilization was only 23% compared to industry average of 70%. Only actual forex losses should be treated as operating expenses, not notional losses. The tribunal excluded one comparable company but included another in software development segment analysis. Higher depreciation rate of 60% was allowed on software applications. Reimbursement of seconded employee costs was held not liable for section 40(a)(i) disallowance as TDS was already deducted under section 192. en-us Fri, 06 Jun 2025 00:00:00 +0530 Wed, 02 Jul 2025 08:42:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774045 ITAT Chennai ruled in favor of the assessee on multiple transfer pricing and tax issues. The tribunal held that reduced sales to associated enterprises cannot justify rejecting idle capacity adjustments, particularly during global recession when the assessee's capacity utilization was only 23% compared to industry average of 70%. Only actual forex losses should be treated as operating expenses, not notional losses. The tribunal excluded one comparable company but included another in software development segment analysis. Higher depreciation rate of 60% was allowed on software applications. Reimbursement of seconded employee costs was held not liable for section 40(a)(i) disallowance as TDS was already deducted under section 192. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774045