https://www.taxtmi.com/caselaws?id=463219 Capacity utilisation adjustment for transfer pricing benchmarking in a start-up manufacturing context is a permissible adjustment where comparables exhibit materially higher capacity utilisation; applying the adjustment increases the assessee's net comparable profit margin to a level comparable with selected Indian comparables, thereby validating the arm's length outcome. The transfer pricing officer's rejection of the capacity utilisation adjustment was reversed on review because the assessee supported the computation methodology, data and precedents; consequently the benchmarking adjustment made by the officer was deleted and the revenue grounds were dismissed. en-us Fri, 02 Jun 2023 00:00:00 +0530 Tue, 20 Jan 2026 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463219 Capacity utilisation adjustment for transfer pricing benchmarking in a start-up manufacturing context is a permissible adjustment where comparables exhibit materially higher capacity utilisation; applying the adjustment increases the assessee's net comparable profit margin to a level comparable with selected Indian comparables, thereby validating the arm's length outcome. The transfer pricing officer's rejection of the capacity utilisation adjustment was reversed on review because the assessee supported the computation methodology, data and precedents; consequently the benchmarking adjustment made by the officer was deleted and the revenue grounds were dismissed. Case-Laws Income Tax Fri, 02 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463219