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    <title>TNMM comparability requires idle capacity and working capital adjustments to reflect ramp-up conditions and actual operating cycle.</title>
    <link>https://www.taxtmi.com/highlights?id=99000</link>
    <description>Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party&#039;s actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.</description>
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    <pubDate>Tue, 21 Apr 2026 17:35:06 +0530</pubDate>
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      <title>TNMM comparability requires idle capacity and working capital adjustments to reflect ramp-up conditions and actual operating cycle.</title>
      <link>https://www.taxtmi.com/highlights?id=99000</link>
      <description>Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party&#039;s actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.</description>
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      <pubDate>Tue, 21 Apr 2026 17:35:06 +0530</pubDate>
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