https://www.taxtmi.com/caselaws?id=794058 Under TNMM, working capital and capacity utilisation adjustments in transfer pricing benchmarking should be quantified on the available record rather than rejected merely for imperfect data. The Tribunal noted that the assessee's financials indicated capacity under-utilisation and held that the TPO could seek further information and adopt a suitable method for quantification instead of denying the claim for want of exact substantiation. It found that ignoring the effect of such adjustments on margins was inconsistent with Rule 10B(e) of the Income-tax Rules, 1962. The matter was restored to the TPO for fresh benchmarking and determination after giving due opportunity. en-us Thu, 30 Apr 2026 00:00:00 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794058 Under TNMM, working capital and capacity utilisation adjustments in transfer pricing benchmarking should be quantified on the available record rather than rejected merely for imperfect data. The Tribunal noted that the assessee's financials indicated capacity under-utilisation and held that the TPO could seek further information and adopt a suitable method for quantification instead of denying the claim for want of exact substantiation. It found that ignoring the effect of such adjustments on margins was inconsistent with Rule 10B(e) of the Income-tax Rules, 1962. The matter was restored to the TPO for fresh benchmarking and determination after giving due opportunity. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794058