https://www.taxtmi.com/caselaws?id=802311 Transfer-pricing operating margins require comparability adjustments for material differences in capacity utilisation under the transactional net margin method, because fixed costs are spread over different production volumes. Capacity-utilisation information may be obtained from comparable companies to assess the adjustment. Operating-margin calculations also require consistent treatment of income and related expenditure: costs incurred to earn R&D fees treated as non-operating are excluded from operating costs. en-us Wed, 23 Sep 2026 00:00:00 +0530 Wed, 04 Nov 2026 08:42:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802311 Transfer-pricing operating margins require comparability adjustments for material differences in capacity utilisation under the transactional net margin method, because fixed costs are spread over different production volumes. Capacity-utilisation information may be obtained from comparable companies to assess the adjustment. Operating-margin calculations also require consistent treatment of income and related expenditure: costs incurred to earn R&D fees treated as non-operating are excluded from operating costs. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802311