Arm's Length Price Recomputed Using TNMM; Assessee's Plea Rejected Due to Lack of Evidence on Employee Utilization Rate.

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....Re-computation of the ALP - idle capacity - PO used the TNMM as the most appropriate method for calculating the ALP - assessee could not point out that the utilization of employees by the comparable companies was less than the assessee - please of assessee rejected - AT....