https://www.taxtmi.com/caselaws?id=790174 Under TNMM, comparability must neutralise material differences in capacity utilisation and operating cycle effects. Idle capacity adjustment in the EPC segment was warranted where the taxpayer showed ramp-up in operations, under-absorption of fixed costs, and a supported methodology, and the denial was therefore unsustainable. Working capital adjustment also had to capture all relevant operating current assets and liabilities, including items such as unbilled revenue, prepaid expenses, customer advances, advance recoverables and inventories, because they affect liquidity and profitability; the computation was therefore to be recomputed on the correct operating base. Only consequential verification by the tax authorities remained. en-us Fri, 09 Jan 2026 00:00:00 +0530 Tue, 21 Apr 2026 08:48:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790174 Under TNMM, comparability must neutralise material differences in capacity utilisation and operating cycle effects. Idle capacity adjustment in the EPC segment was warranted where the taxpayer showed ramp-up in operations, under-absorption of fixed costs, and a supported methodology, and the denial was therefore unsustainable. Working capital adjustment also had to capture all relevant operating current assets and liabilities, including items such as unbilled revenue, prepaid expenses, customer advances, advance recoverables and inventories, because they affect liquidity and profitability; the computation was therefore to be recomputed on the correct operating base. Only consequential verification by the tax authorities remained. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790174