TP Adjustment made by excluding two comparable companies due to ...

TP adjustment excludes incomparable companies due to related party transactions. Cost allocation change disallowed. 25% depreciation on intangible assets allowed.

Case Laws Income Tax

August 13, 2024

TP Adjustment made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.

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TP Adjustment made by excluding two comparable companies due to ...

TP adjustment excludes incomparable companies due to related party transactions. Cost allocation change disallowed. 25% depreciation on intangible assets allowed.

Case Laws Income Tax

August 13, 2024

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