ALP couldn't be adjusted in under-utilized capacity; doing so would deem perfect business conditions

IT/ILT : In view of provisions of Rule 10B(1)(e)(iii) of Income-tax Rules, 1962, relief granted by Commissioner (Appeals) by making adjustments on account of capacity under utilisation in results shown by tested party i.e. assessee herein and thus computing hypothetical financial results which tested party would have achieved in perfect conditions was impermissible in law