The Tribunal held that with regard to adjustment made towards under-utilisation of capacity for the manufacturing segment, the assessee had utilised only 41 per cent. of its installed capacity during the year. Though the assessee had not mentioned about the capacity utilisation achieved by the comparable companies, the assessee should be allowed capacity utilisation adjustment. The Tribunal held that the claims with regard to payment made for group services were interlinked with each other, and the issues were to be restored to the Assessing Officer/Transfer Pricing Officer for examination afresh. The Tribunal held that that with regard to the error in computation of the net margin on cost of comparable companies, the claim of the assessee that the Transfer Pricing Officer had computed the net margin on cost of comparables as 8.16 per cent. while the actual margin worked out to 9.10 per cent. required verification. The Tribunal held that the issue with regard to disallowance of working capital adjustment was restored to the file of the Assessing Officer/Transfer Pricing Officer with the direction to allow working capital adjustment on actual basis. It was further held that the mistake in treating the foreign exchange gain as foreign exchange loss and including it as part of cost was a computational mistake, required to be corrected in order to arrive at the correct margin. It was also held that the transfer pricing adjustment to the sales made to associated enterprises, under the transactional net margin method was required to be restricted to international transactions only. (AY.2009-10)