Transfer Pricing: Revenue can’t adjust operating costs in allowing capacity adjustment

Brief of the case:

In the case of DCIT Vs. Claas India Pvt. Ltd. Delhi Bench of ITAT have denied to approve the method adopted by AO/TPO in allowing capacity adjustments. ITAT further held that once the law enjoins for doing a particular thing in a particular manner alone, it is not open to anyone to adopt a contrary or different approach. ITAT observed that lower authorities have adjusted the operating costs of the assessee in allowing the capacity adjustment. Further ITAT elaborate the method to compute capa

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