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2016 (8) TMI 1582 - AT - Income TaxTP Adjustment - Comparable selection - international transaction pertaining to provision of software development services undertaken by the assessee with its AE - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected. Depreciation on UPS - treating it as ‘Plant and Machinery’ eligible for 15% rate of deprecation as against the claim of 60% made by the assessee on the ground that, the same has to be treated as part of the computer - HELD THAT:- Before us, nothing has been brought on record to the on the fate of such a finding given by the DRP in the AY 2009-10. Once in the earlier year, depreciation has been allowed @ 15% not 60%, then no different stand can be taken in this year, because depreciation has to be allowed on WDV. Accordingly, ground as taken by the assessee is treated as dismissed.
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