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2013 (11) TMI 65 - ITAT DELHIAdjustment for non-utilisation of capacity in an International transaction - Lower authorities to have given due effect to under capacity utilization of the assessee which has not been done TPO for adjustment for ALP determination – Held that:- Suitable adjustment for non-utilisation of capacity is to be taken in to account after considering the ALP while working out TP adjustment, this proposition has been held by co-oridnate Bench in the case of the Amdocs Business Services (P.) Ltd. [2012 (12) TMI 482 - ITAT PUNE] - Restored the issue of under capacity utilization back to the file of the Assessing Officer /TPO to decide the same afresh after giving assessee adequate opportunity of being heard.
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