https://www.taxtmi.com/caselaws?id=798022 COVID-19-induced underutilisation of a captive service provider's manpower and infrastructure can warrant a capacity-utilisation adjustment under TNMM where abnormal idle costs materially depress operating margins. Rule 10B(3) permits reasonably accurate adjustments for material profit-affecting differences and does not require publicly available identical capacity-utilisation or idle-cost data for comparables. Reasonable economic estimation is sufficient where the idle costs, their business nexus and computation are demonstrated and reliable. Neutralising the abnormal idle costs produced an operating margin of 14.25%, exceeding the comparable median of 11.84%; the international transactions were therefore at arm's length and required no transfer-pricing adjustment. en-us Mon, 24 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798022 COVID-19-induced underutilisation of a captive service provider's manpower and infrastructure can warrant a capacity-utilisation adjustment under TNMM where abnormal idle costs materially depress operating margins. Rule 10B(3) permits reasonably accurate adjustments for material profit-affecting differences and does not require publicly available identical capacity-utilisation or idle-cost data for comparables. Reasonable economic estimation is sufficient where the idle costs, their business nexus and computation are demonstrated and reliable. Neutralising the abnormal idle costs produced an operating margin of 14.25%, exceeding the comparable median of 11.84%; the international transactions were therefore at arm's length and required no transfer-pricing adjustment. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798022