https://www.taxtmi.com/caselaws?id=466062 Tribunal directives on transfer pricing require reworking operating margins by treating forex gain on export turnover as part of operating margin, and mandate computation of low capacity utilisation adjustments limited to costs attributable to idle capacity, with the assessee to supply capacity utilisation details for both the taxpayer and comparables for any adjustment. Risk adjustment must be considered as a component of FAR analysis based on details furnished by the assessee. The tribunal adopted an arm's length commission for corporate guarantee at 0.5%. A precedent was cited restricting maintenance of appeals absent ex facie perversity in ITAT findings. en-us Thu, 16 Aug 2018 00:00:00 +0530 Tue, 20 Jan 2026 12:53:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466062 Tribunal directives on transfer pricing require reworking operating margins by treating forex gain on export turnover as part of operating margin, and mandate computation of low capacity utilisation adjustments limited to costs attributable to idle capacity, with the assessee to supply capacity utilisation details for both the taxpayer and comparables for any adjustment. Risk adjustment must be considered as a component of FAR analysis based on details furnished by the assessee. The tribunal adopted an arm's length commission for corporate guarantee at 0.5%. A precedent was cited restricting maintenance of appeals absent ex facie perversity in ITAT findings. Case-Laws Income Tax Thu, 16 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466062