https://www.taxtmi.com/caselaws?id=466018 Transfer pricing adjustment on idle capacity and comparable selection: tribunal found appellate findings cryptic and noted assessee filed an affidavit describing idle capacity; it held that AO/TPO may procure idle capacity data of comparables through statutory requisition and the assessee may produce industry-level idle capacity data; if the assessees idle capacity is substantially higher than the industry average, an idle capacity adjustment should be made. The matter was remitted to the appellate authority for fresh decision, with other issues left open and appeals allowed for statistical purposes. en-us Fri, 08 Nov 2019 00:00:00 +0530 Tue, 20 Jan 2026 21:18:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466018 Transfer pricing adjustment on idle capacity and comparable selection: tribunal found appellate findings cryptic and noted assessee filed an affidavit describing idle capacity; it held that AO/TPO may procure idle capacity data of comparables through statutory requisition and the assessee may produce industry-level idle capacity data; if the assessees idle capacity is substantially higher than the industry average, an idle capacity adjustment should be made. The matter was remitted to the appellate authority for fresh decision, with other issues left open and appeals allowed for statistical purposes. Case-Laws Income Tax Fri, 08 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466018