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2015 (4) TMI 502 - ITAT DELHI

2015 (4) TMI 502 - ITAT DELHI - TMI - Transfer pricing adjustment - most appropriate method - CUP method OR TNMM - Held that:- assessee chose CUP as the most appropriate method in respect of twelve international transactions, but, the TPO simply brushed aside the assessee's choice of the most appropriate method and proceeded to determine the arm's length price of all the fourteen transactions under the TNMM, without giving any reason whatsoever, much less any cogent and rational reasons, .....

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the matter to the file of AO/TPO for determining the ALP of the twelve international transactions, firstly, under the CUP method as was substantively chosen by the assessee as the most appropriate method.

Determination of the operating profit margin of the assessee - not allowing of deduction for the abnormal operating costs for the three months period of strike - Held that:- the net operating profit margin realized by the assessee from its international transaction is to be computed .....

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was not hit by any untoward incident. Such southwards adjustment in the assessee's own operating costs and the resultant northwards movement in its own profit rate, is impermissible under the law. In view of the foregoing reasons, we uphold the view taken by the TPO in rejecting the claim of the assessee for reduction of the so-called abnormal operating costs from the total operating costs.

Adjustment to the operating profits of the assessee by the amount of depreciation - Held t .....

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he comparable companies have charged depreciation at a lower rate in comparison with the assessee, then suitable increase should be made to their amount of depreciation. In doing so, the TPO should see if he can correctly deduce the amount of depreciation on the above lines. If due to one reason or the other, such precise calculation is not possible or the assessee fails to place it before him, then no adjustment should be carried out in the calculation of the operating profits of the comparable .....

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edominant sale of this company in the three wheeler segment has turned out to be incorrect, we see no justifiable reasons in overruling the view taken by the TPO in considering Bajaj Auto Ltd. as comparable, which is hereby affirmed. This contention of the ld. AR on this aspect is repelled.

International transaction of Purchase of fixed asset - Held that:- International transaction of purchase of fixed assets is required to be benchmarked as per the most appropriate method. The applic .....

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on of the ALP of the international transaction of purchase of fixed assets and direct that the depreciation on such fixed assets be computed on the adjusted value, if permissible, as per the relevant provisions. Needless to say, the assessee will be allowed a reasonable opportunity of being heard in such fresh proceedings.

Depreciation on Moulds used in plastic goods factory - Held that:- AO reduced the depreciation rate on plastic moulds by following the view taken by him in the prec .....

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l purposes. - IT APPEAL NO. 1379 (DELHI) OF 2011 - Dated:- 13-4-2015 - R.S. SYAL AND GEORGE GEORGE K., JJ. For The Assessee : Shri Vijay Iyer, CA For The Department : Shri Judy James, Standing Counsel ORDER Per R.S. Syal, AM: - This appeal by the assessee is directed against the final order passed by the Assessing Officer u/s 143(3) read with section 144C of the Income-tax Act, 1961 (hereinafter also called 'the Act') on 14.02.2011 in relation to the assessment year 2006-07. 2. The first .....

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ooters in India. Honda, Japan provides necessary technology and support to the assessee for manufacturing two-wheelers in India. The manufacturing activity is undertaken by the assessee and the goods so manufactured, namely, two wheelers, are largely sold in India to unrelated parties and some part of the total sale is exports made both to Associated enterprises (AEs) and non- associated enterprises (non-AEs). The assessee reported the following fourteen international transactions with Honda and .....

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chnical know-how fee CUP/ TNMM - 18,88,50,000 7. Payment of technical assistance fee CUP/ TNMM - 2,42,24,247/- 8. Authorised test support fee CUP/ TNMM - 9,39,717/- 9. Service fee CUP/ TNMM - 28,87,498 10. Owner's manual charges CUP/ TNMM - 34,13,309 11. Prototypic Development CUP/ TNMM - 69,05,820 12. Reimbursement of expenses CUP/ TNMM - 21,74,230 13. Warranty on scooters CUP/ TNMM - 1,89,59,146 14. Recovery of expenses CUP/ TNMM - 4,64,06,214 4. Certain comparables instances were given in .....

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the analysis of five comparable companies with their respective profit margins, as under :- S.No. Name of companies Year ended Operating profit/sales (%) 1. Kinetic Motor Company Ltd. 30.09.2005 (15.51) 2. LML Limited 31.03.2005 (20.60) 3. TVS Motor Company Ltd. 31.03.2006 7.64 4. Majestic Auto Ltd. 31.03.2006 4.75 5. Kinetic Engineering Ltd. 30.09.2005 (9.84) Average (OP/Sales%) (6.71) Average of OP/Sales % of comparable companies -6.71% OP/sales of the assessee company 7.16% 5. In view of the .....

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fficer (TPO) rejected Kinetic Motor Company Ltd., LML Ltd. and Kinetic Engineering Ltd. from the list of comparables because of non-availability of their relevant data for the year ending 31.03.2006. Apart from retaining the other two companies, namely, TVS Motor Company Ltd. and Majestic Auto Ltd., the TPO expanded the list of comparables by also including Bajaj Auto Ltd. This company was included in the list of comparables for the reason that the assessee itself treated this company as compara .....

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e computed the assessee's operating profit margin at 0.32% by, inter alia, including the amount of depreciation as part of operating cost, which was not considered by the assessee in its original calculation. A transfer pricing adjustment of ₹ 19,53,79,302 was computed by applying the differential profit rate of 7.12% (7.44% minus 0.32%) on the total value of all international transactions reported by the assessee at ₹ 274,40,91,319. In other words, the TPO applied Transactional .....

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3 by considering the TNMM as the most appropriate method. The assessee remained unsuccessful before the Dispute Resolution Panel (DRP). This eventually led to the making of addition of ₹ 19.53 crore on account of transfer pricing adjustment by the Assessing Officer (AO) in the final order passed u/s 143(3) read with section 144C of the Act. The assessee is aggrieved against the making of addition of ₹ 19.53 crore and odd. 7.1 We have heard the rival submissions and perused the relev .....

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clared value of all the fourteen international transactions at ₹ 274.40 crore and applied the difference between profit margin of the comparables and that of the assessee, as computed by him, for proposing transfer pricing adjustment of ₹ 19.53 crore. In resorting to the TNMM for all the fourteen international transactions, the TPO did not mention any reason worth the name as to why the ALP of twelve international transactions was not determined by him as per the CUP method, which wa .....

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onal transaction shall be computed having regard to the arm's length price.' The procedure for computation of arm's length price has been set out in section 92C. Sub-section (1) of section 92C provides that: 'The arm's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, having regard to the nature of transaction or class of transaction or class of associated persons or functions perfo .....

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9;an' international transaction; and (ii) the ALP of such an international transaction is to be determined by applying the most appropriate method out of the prescribed methods which, inter alia, include CUP and TNMM. The first ingredient is that the ALP should be determined in relation to an international transaction. The term 'international transaction' has been defined in section 92B to mean : 'a transaction between two or more associated enterprises, either or both of whom ar .....

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in section 92F(v) and also in Rule 10A(d) of the Income-tax Rules, 1962. The Rule defines the term 'transaction' to include: 'a number of closely linked transactions.' On going through the above provisions, it becomes palpable that the arm's length price is essentially determined on transaction-by-transaction approach for each international transaction separately; and for that purpose, a transaction in singular also includes plural for closely linked transactions. In other wo .....

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s, which is the most appropriate method having regard to the nature of transaction or class of transaction or functions performed, etc. It is impermissible to combine all the international transactions for determining their ALP in a unified manner when such transactions are diverse in nature. 7.3 Adverting to the facts of the instant case, we find from the nature of international transactions reproduced above that these include Purchase of spare parts; Export of scooters and scooter parts; Purch .....

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aimed twelve out of the total international transactions at ALP by using the CUP as the most appropriate method. The TPO, without assigning any reason as to why the CUP method could not be applied, went ahead by determining the ALP of all the international transactions under TNMM on a consolidated manner. 7.4 It goes without saying that it is the assessee who knows best about the most appropriate method for a particular international transaction undertaken by him. It is his prerogative to initia .....

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P under such a chosen method, is properly available. Then, comes the turn of the AO/TPO to satisfy himself that not only the correct method has been applied by the assessee but also that proper data for determination of ALP under such method has also been made available. If the Officer gets satisfied on the above aspects, the matter ends. If, however, the Officer comes to a conclusion that either the method employed by the assessee for determining the ALP is not the most appropriate method or th .....

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s only if the Officer is not satisfied with such choice, that he can reject such a method and proceed to determine the ALP under another more appropriate method. However, before applying another method, it is incumbent upon the Officer to give some plausible and convincing reasons for rejecting the method selected by the assessee. The Officer cannot arbitrarily reject the assessee's choice of method and substitute it with another method, which he considers as the most appropriate method. 7.5 .....

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e of action adopted by the TPO is unknown to the law. Without expressly rejecting the assessee's contention about the applicability of the CUP as the most appropriate method in respect of twelve international transactions, the TPO could not have proceeded to determine the ALP of these twelve international transactions also under the TNMM. Under such circumstances, we have no option but to set aside the impugned order and remit the matter to the file of AO/TPO for determining the ALP of the t .....

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ke it clear that we have eschewed from undertaking the exercise of checking the applicability or otherwise of the CUP method to such twelve international transactions or examining the availability or suitability of the data of comparable uncontrolled transactions given by the assessee. In other words, the entire exercise has been left open to be done by the TPO as per law. 8. Now, we are left with the remaining two international transactions, viz., 'Purchase of motorcycles, scooter parts, co .....

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eing, first, the determination of the operating profit margin of the assessee and second, exclusion/inclusion of some companies as comparable. 9. Firstly, we espouse the determination of the operating profit margin of the assessee, which has two disputed aspects, namely, not allowing of deduction for the abnormal operating costs for the three months period of strike; and improper grant of depreciation allowance. 10.1 The assessee determined its adjusted OP/sales at 7.16% by reducing the total op .....

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to reduce the said sum of ₹ 23.91 crore from the total operating costs in working out the assessee's profit rate. The ld. AR vehemently argued that the strike during these three months period of June to August, 2005 crippled the functioning in the factory and, as such, it was essential to reduce the operating costs with the proportionate decline in the turnover during this period. Au contraire, the ld. DR. strongly supported the impugned order. 10.2 We are not inclined to accept the c .....

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e by applying 56% to the total operating costs incurred during this period of three months. This 56% was determined by considering the ratio of actual sales during these three months to the normal sales during such period. Prima facie, going by the assessee's own version, it should have been in the ratio loss of sale to the normal sales and not actual sales to normal sales. The ld. AR candidly conceded this position during the course of hearing before us. Be that as it may, we find that ther .....

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roduction for the month of May, 2005 stood at 57063, that of June at 32217, July at 14853, August at 44173, September at 60225, November at 54597 and December, 2005 at 39170. It is patent that that the average production during these three months period at 30415 is quite close to the normal production during December, 2005 at 39170. Even during the normal working, the production is fluctuating and not static. Further, the assessee has not shown the figures of production during the corresponding .....

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le 10B(e), which contains the modus operandi of determining the ALP of an international transaction under the TNMM, as under:- "(e) transactional net margin method, by which,- (i) the net profit margin realised by the enterprise from an international transaction entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise or having regard to any other relevant base ; (ii) the net profit margin r .....

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terially affect the amount of net profit margin in the open market ; (iv) the net profit margin realised by the enterprise and referred to in sub-clause (i) is established to be the same as the net profit margin referred to in sub-clause (iii) ; (v) the net profit margin thus established is then taken into account to arrive at an arm's length price in relation to the international transaction." 10.4 Sub-clause (i) in the determination of ALP under TNMM is the computation of net operatin .....

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lip; which could materially affect the amount of net profit margin in the open market.' It is this adjusted net profit margin of the unrelated transactions or of the comparable companies, as determined under sub-clause (iii), which is used for the purposes of making comparison with the net profit margin realized by the assessee from its international transaction as per sub-clause (i). Sub-rule (2) of Rule 10B provides that the comparability of an international transaction with an uncontrolle .....

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hich emerges is that the net operating profit margin of the comparable companies calls for adjustment in such a manner so as to bring both the international transaction and comparable cases at the same pedestal. In other words, if there are no differences in these two, then the net operating profit margin of the comparable companies should be considered as a benchmark. However, in case there is some difference, then such difference should be ironed out by making suitable adjustment to the operat .....

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other way around to adjust the profit margin of the assessee. In other words, the net operating profit margin realized by the assessee from its international transaction is to be computed as such, without adjusting it on account of differences between its international transactions and the comparable uncontrolled transactions. The adjustment, if any, is required to be made only in the profit margin of the comparables, and that too, by demonstrating some difference between international transacti .....

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or reduction of the so-called abnormal operating costs from the total operating costs. 11.1 Now, we take up the second issue of adjustment to the operating profits of the assessee by the amount of depreciation. The ld. DR submitted that depreciation ought not to have been allowed to the assessee. We fail to appreciate this contention for the reason that depreciation is an integral part of the operating costs. Even though the assessee initially did not consider the amount of depreciation allowanc .....

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fit margin, thereby requiring an upward increase in the amount of depreciation of the comparables and the resultant reduction in their operating profit margins. 11.3 Schedule XIV to the Companies Act provides for rates of depreciation on various assets under different blocks, both on written down value method and straight line method. We appreciate that sub-clause (iii) of Rule 10B(e) provides that the net profit margin realized by a comparable company, determined as per sub-clause (ii) above, i .....

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can be no dispute on the principle that calculation of 'Operating profit' as envisaged under Rule 10B(1)(e) embraces cumulative effect of all the items of income and expenses which are of operating nature. Ordinarily, there can be no question of considering each item of such operating expenses or income in isolation de hors the other expenses to claim adjustment on the ground of such expenditure or income of the assessee on the higher side seen individually or as a percentage of other op .....

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l pay rent which will find its place in the operating costs. For the purposes of making comparison, one cannot contend that the payment of rent by one enterprise in comparison with a non-payment of rent by another, should be neutralized by giving proper adjustment from the operating profit of the comparable. The manifest reason is that the other enterprise may have its own office premises and in that case, the amount of depreciation on such premises will also form part of its operating cost. Whe .....

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ts with lower amount of depreciation. No adjustment on account of difference in the amounts of depreciation of two companies is called for when the operating profits are determined because in the case of a company having purchased new asset, there will be lower repair cost and vice versa. The effect of all the individual items of operating expenses and incomes culminates into the overall operating profit margin. That is why, the legislature has provided for comparing the ratio of 'operating .....

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ing profit margin under the TNMM of the assessee as well as comparables, the higher or lower volume of two companies becomes immaterial and so is the quantum of depreciation. The nitty-gritty of the matter is that no adjustment can be allowed simply for the reason that one company has charged higher amount of depreciation vis-a-vis its comparable companies. Not only no adjustment on this score is permissible, the assessee cannot also seek an exclusion or inclusion of a company on the ground that .....

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depreciation on its assets in conformity with the rates prescribed in Schedule XIV of the Companies Act and other company may adopt a policy of charging depreciation at the higher rates or lower than those prescribed under Schedule XIV. This can be demonstrated with the help of an example. Other things being equal, if the operating profit of company A, after claiming depreciation of ₹ 10 on the value of asset worth ₹ 50 with rate of depreciation 20%, is ₹ 100, the operating pr .....

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due to higher or lower rate of depreciation, thereby distorting their comparability. It is this difference in the amounts of depreciation due to different rates of depreciation and not due to different quantum of depreciation simiplicitor, which calls for bringing both the companies at par. 11.6 Reverting to the facts of the extant case, we find that the TPO did not have any occasion to consider this issue, because such an argument has been advanced before us for the first time. In our considere .....

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he rates at which the assessee has provided depreciation. To clarify, if the comparables have charged depreciation at a higher rate in comparison with the assessee on some of its assets, then suitable reduction should be made in the amount of their depreciation. The TPO should not equally hesitate to make adverse adjustment, if warranted, which means that if the comparable companies have charged depreciation at a lower rate in comparison with the assessee, then suitable increase should be made t .....

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mpanies are using the SLM and there is some difference in the rates of depreciation charged by them vis-à-vis the assessee, then suitable adjustment should be made to the profits of the comparables. 12.1 Now, we take up the objection of the ld. AR on the question of the comparables. It can be noticed from the factual matrix discussed above that the assessee initially chose five companies as comparable, out of which three were excluded by the TPO for want of the availability of their neces .....

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cing study report as well as its reproduction on page 4 of the TPO's order that the data of these three companies was not given for the year ending 31.3.2006. Whereas the data for Kinetic Motor Company Ltd. and Kinetic Engineering Ltd. was given for the year ending 30.9.2005, the assessee provided data of LML Ltd. for preceding year ending 31.3.2005. It is obvious that in the absence of the relevant data for the year ending 31.3.2006, these companies were liable to be excluded. Primarily, we .....

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.3 The ld. Counsel for the assessee contended that though at the material time the relevant data for the current year of these three companies was not available, but, now the assessee can produce the relevant data. We find from the TPO's order that he has excluded these three companies only for the non-availability of the data for the current year. The otherwise comparability of these companies is not in dispute. Under such circumstances, we set aside the impugned order and direct the TPO to .....

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ind that the viewpoint of the Revenue in treating this company as comparable, is perfectly in order. It is clear that the assessee itself chose Bajaj Auto Ltd. as one of the comparables for the immediately preceding year. Once a company is considered as comparable in an earlier year and there is nothing to justify shift from such stand, no change can be permitted in so far as inclusion of such company in the list of comparables for the succeeding year is concerned. The ld. AR argued that Bajaj A .....

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ale of this company in the three wheeler segment has turned out to be incorrect, we see no justifiable reasons in overruling the view taken by the TPO in considering Bajaj Auto Ltd. as comparable, which is hereby affirmed. This contention of the ld. AR on this aspect is repelled. 13. Our above directions will facilitate the computation of profit margin of the assessee and those of comparables. 14. Now, we come to the remaining two international transactions, namely, Purchase of motorcycle/scoote .....

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f the operating profit margin of the assessee and that of comparables as determined in the light of our above directions. If the difference between two margins breaches the safe harbor rule, then, the addition on account of TP adjustment should be made. 15.1 Coming to the international transaction of Purchase of fixed asset, it is seen that the assessee recorded it at ₹ 21.37 crore and showed it as ALP under the TNMM. We have laid down the mechanism for computation of ALP of such transacti .....

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ction and then applying the differential profit rate of 7.12% on such value. In other words, the addition has been made on the value of international transaction of the purchase of fixed assets. The ld. AR contended that the TPO was not justified in proposing the transfer pricing adjusting w.r.t. the value of purchase of fixed assets. It was argued that only the depreciation element of such adjusted value of the international transaction of purchase of fixed assets would call for adjustment to t .....

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tion (2) inserted by the Finance Act, 2012 w.r.e.f. 1.4.2002 clarifies, for the removal of doubts that - (i) the expression "international transaction" shall include - (a) the purchase, sale, transfer, lease or use of tangible property including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing. In view of the above plain and unambiguous language of the provision read with its Explanation, it is abundantly .....

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mputed having regard to the ALP. To put it simply, section 92 is not a charging but a procedural provision for recomputing the income arising from an international transaction having regard to its ALP. Before applying the mandate of this provision, it is of utmost importance that there should be some existing income chargeable to tax, which is sought to be recomputed having regard to its ALP. If there is an international transaction which in itself gives rise to income that is chargeable to tax, .....

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transaction. At the same time, it does not mean that the computation of the ALP of such an international transaction in the capital field is just a ritual and should not be embarked upon. In fact, such a computation is necessary because of the impact of such a transaction of capital nature on the transactions of its revenue offshoots. In our present context, the international transaction of purchase of fixed assets is required to be benchmarked as per the most appropriate method. The applicatio .....

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f the ALP of the international transaction of purchase of fixed assets and direct that the depreciation on such fixed assets be computed on the adjusted value, if permissible, as per the relevant provisions. Needless to say, the assessee will be allowed a reasonable opportunity of being heard in such fresh proceedings. 16.1 Ground no. 4 of the assessee's appeal is against allowing depreciation on Moulds used in plastic goods factory at ₹ 1.35 crore as against ₹ 2.37 crore claimed .....

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