9911796707
TMI Blog2023 (6) TMI 175X X X X Extracts X X X X X X X X Extracts X X X X ..... ternational transaction of payment for information technology consultancy charges to the AE of the assessee amounting to Rs. 4,84,28,143/-, the ALP of which was determined by the TPO at NIL, holding, it was only in the nature of stewardship and supervisory services. All these grounds are being dealt with by us together. The said grounds read as under: 1. On the facts and in the circumstances of the case and in law, the Learned Income-tax Officer, Ward-1 (1)(3), Ahmedabad ('Ld. AO') and the Learned Deputy Commissioner of Income-tax, Transfer Pricing Officer- II ('Ld. TPO') under the directions of Honourable Dispute Resolution Panel ('Hon'ble DRP'), erred in making an upward adjustment of Rs. 1,47,36,729/- in relation to the international transaction of payment of Information Technology Consulting Charges to Associated Enterprise ('AE'). The Appellant prays that the additions made by the Ld. AO / TPO in relation to the international transactions of payment of intra-group services to AE be deleted. 2. On the facts and in the circumstances of the case and in law, the Ld. AO / TPO under the directions of Hon'ble DRP erred in making the adjus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the aforesaid addition be deleted. 8. On the facts and in the circumstances of the case and in law, the Ld. AO under the directions of Hon'ble DRP erred in disallowing devaluation of inventory amounting to Rs. 1,79,46,564. While making the addition, the Ld. AO erred in law and on facts on the following: i. in disregarding the stock valuation made by the Appellant as per AS 2 and section 145A of the Act; ii. in not appreciating the fact that no adverse remark is made by the Auditors in the audit report; iii. in disregarding the contention of the Appellant that the current method of valuation of inventory has been followed consistently over the past years; The Appellant prays that the aforesaid addition be deleted. 9. On the facts and in the circumstances of the case and in law, the Ld. AO under the directions of Hon'ble DRP erred in capitalising interest expense amounting to Rs. 59,12,913 to the capital work-in-progress ('CWIP') without any basis. It is prayed that the interest be allowed u/s 36(1)(iii) of the Act since it is for the purpose of business." 4. The ld.counsel for the assessee before us contended that IT consultancy expenses to the tune o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... RIL are availed in both the segments i.e. Manufacturing and Trading segments. Hence the value of these international transactions has been allocated between manufacturing and trading activities by using sales value as a basis of allocation. Sales made by the manufacturing division are INR 207.57 crores and trading division is INR 185.89 crores i.e. the allocation ration being 50.89/6 and 49.11% respectively. 6. Sample invoices for the service are enclosed herewith as Annexure - K 1.1 5. Our attention was drawn to various invoices raised on account of the said services by its AE placed at PB Page No. 120 to 124 and also agreement for rendering of services of AE, placed before at PB Page No. 115 to 117. Our attention was also drawn to the list of employees who worked on the SAP project placed before us at PB page no. 522; schedule of sessions conducted during the implementation of SAP at page no. 523 to 524; minutes of meeting reflecting trouble shoot/guidance of different modules of SAP at PB page no. 525 to 553, and certificate from hotel for stay of personal engaged in SAP implementation was also filed and placed before us at PB Page No. 554 to 555, which were submitted to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the basis that quantum of charges paid by the assessee for these services was disproportionately higher in relation to the cost of the software for the implementation of which these services were procured by the assessee. He pointed out that the DRP had taken note that while software purchased for Rs. 2.91 crores, the maintenance cost claimed by the assessee as IT consultancy charges, was as high as Rs. 1.47 crores, and based on this, the DRP held that the assessee actually had not received any benefit on this count. The ld.counsel for the assessee contended that this cannot be the basis for holding that the assessee had not procured any service on account of IT consultancy, more particularly, when all evidences in this regard, as noted above, were filed by the assessee. The ld.DR on the other hand relied on the order of the DRP/TPO. 8. We have heard both the parties; we have also carefully considered submissions made by the assessee to the TPO/DRP. We find merit in the contention of the Ld.Counsel for the assessee that the AO/DRP had erred in determining the ALP of the international Transaction of Information Technology Consulting Charges at NIL as opposed to Rs. 1,47,36,729/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the evidences did not establish nature of services rendered. 9. In view of the same, we do not agree with the AO/DRP that no services were rendered by the AE to the assessee on account of IT consultancy services, and we therefore, direct the deletion of the adjustment made to the same by treating the ALP of the said services at NIL as opposed to Rs. 1,47,36,729/- claimed by the assessee. In view of the above, ground nos.1, 2 & 3 raised by the assessee are allowed. 10. Ground No. 4 raised by the assessee reads as under: 4. On the facts and in the circumstances of the case and in law, the Ld. AO / TPO under the directions of Hon'ble DRP, erred in making adjustment of Rs. 52,91,667/- in relation to the international transaction of payment of guarantee fees to AE. 11. The issue involved in this ground relates to the TP adjustment made in relation to international transactions of payment of guarantee fees by the assessee to its AE amounting to Rs. 52,91,667/- the Arms Length Price(ALP) of which was determined at NIL by AO/TPO, objection of the assessee to which, was dismissed by the DRP. 11. The facts relating to the issue are that during the impugned year, the assessee ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icient reserves and no lender, in such circumstances, would have asked for any guarantee fee on giving loans to the assessee. The assessee was found to be in a very sound financial position by the TPO. Thirdly, the TPO noted that the loan had been made for acquiring capital assets, and in such a situation he found that, the capital asset itself would have sufficed as collateral securities for the loan, and there was no requirement for any guarantee fee to be given by any party. He also noted that there was neither any insistence by the lender for guarantee, and as per the assessee it appeared to have been given more as a unilateral group policy for imposing guarantee fees on the assessee. His detailed findings in this regard at para 5(a) to 5(e) are as under: 16. His finding to the effect that no benefit accrued to the assessee on account of guarantee is based on the facts noted by him that the loan was advanced to the assessee at PLR and considering that the assessee was in financially sound position, it was normal for banks to advance loan on discount at PLR, and therefore, in the present case no distinct benefit on account of guarantee seemed to be fastened on the assessee-comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g to the payment of guarantee commission that it was all an arrangement between the AE of the entities itself is not disputed, the lender being an AE of the assessee, as also the entity providing guarantee to the assessee, all belonging to the same group. It is also not disputed and denied that the assessee was a debt-free company with huge and sufficient reserves as noted by the TPO. There was no necessity demonstrated for guaranteeing of the loan. The service of guarantee in the facts of the case was not needed by the assessee at all as rightly noted by the AO/TPO. Therefore, we agree with the TPO that there was no rendering of any service of guarantee in the present case by the AE to the assessee, warranting payment of guarantee, if at all. Further, it is not denied that the loan had been taken by the assessee for acquiring long term assets i.e. land etc. and therefore, the assets itself could serve as a collateral securities, doing away the need for any guarantee to be provided, more particularly, considering that the assessee was a financially sound company, as the loan could have been sufficiently guaranteed by the collateral securities itself. Also, as rightly noted by the T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmission of the assessee, who held that as per the rate of depreciation prescribed under the Income Tax Rules, 1962 in Part-III of new Appendix, equipments are not covered under the plant & machinery, but they are covered under the category fittings on which rate of depreciation is 10%. Accordingly, he restricted the assessee's claim of depreciation on office equipments to 10% as opposed to 15% claim by the assessee, and excess depreciation so claimed by the assessee amounting to Rs. 11,71,648/- was proposed by the AO to be disallowed in his draft order passed under section 143C of the Act. 26. The assessee objected to the same before the ld.DRP contending that it had been consistently claimed depreciation at the rate of 15% on office equipments which qualified as plant & machinery, and which had been allowed in earlier year also, and further relied on the decision of Hon'ble Punjab & Haryana High Court in the case of CIT Vs. Subrata Dutta Choudhary, 197 taxmann 71 (P&H) in support of his contentions that equipments qualify cannot be treated as office furniture, but qualified as plant & machinery. The Ld.DRP however dismissed the contentions of the assessee, nothing that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e depreciation was claimed by the assessee on office equipments pertained to opening block of asset so qualified as office equipments on which the assessee had claimed depreciation at the rate of 15% in earlier years, and had been consistently allowed by the Revenue. In this regard, our attention was drawn to the Paper Book Page No. 58 of Volume-I of PB being particulars of depreciation allowable as per Income Tax Rules for the impugned year i.e. 2010-11 being part of tax audit report furnished by the assessee, pointing out there from the fact that of the total value of office equipments on which depreciation at the rate of 15% had been claimed by the assessee amounting to Rs. 2,32,52,570/-, an amount of Rs. 2,24,47,127/- represented the opening written down value of the block of asset and the additions made during the year were only to the tune of Rs. 12,10,443/-. The contention of the assessee was that where the assessee's block of asset of office equipments qualifying for depreciation at the rate of 15% had been consistently recognized by the Revenue as being in accordance with the law and rules prescribed in this regard, the block of asset now being shifted by taking a total di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also by the Revenue. The assesseehas consistently pleaded before the Revenue authorities and even before us and this contention of the assessee has never been controverted by the Revenue. Therefore, it is fact on record that out of total WDV of office equipments on which the assessee had claimed depreciation at therate of 15% of Rs. 2.36 crores, Rs. 2.24 crores value of office equipments had all along been allowed depreciation at the rate of 15% by the Revenue in the past. 31. With respect to these assets, we find, the Revenue has changed its stand of asset qualifying for depreciation at the rate of 10% merely on account of change of view that too without any basis. It is not that the Revenue has now come in possession of some details regarding these equipment, which showed that they did not qualify for depreciation at the rate of 15%, butare in the nature of furniture and fittings entitled to depreciation at 10%. It is only description of block of asset as office equipments which has lead the Revenue now to form a different view that being used in office, these equipments qualified as fittings to be included in the block of asset being furniture and fittings, thus qualified depre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... No. 7 raised by the assessee reads asunder: "On the facts and in the circumstances of the case and in law, the Ld. AO under the directions of Hon'ble DRP erred in disallowing provision for advertisement expenses amounting to Rs. 85,500 by considering it as an ad hoc provision without appreciating the break-up of the said expense and the fact that taxes had been withheld and deposited to the credit of government on the said provision amount." 37. Briefly, the facts relating to the issue are that the AO on verification of the details filed by the assessee in respect of advertisement expenses noted that the assessee had made a provision of Rs. 85,500/- on account of advertisement expenses on adhoc basis, holding that provision of this nature are not allowable as expenditure in computing the income. He accordingly proposed disallowance of the said provision made by the assessee. The objection filed by the assessee to the ld.DRP was dismissed by him noting that the assessee-company did not furnish any fresh details to press this ground of objection. The finding of the ld.DRP at para-4 in page no. 32 of his order is as under: "4. The next objection raised is regarding dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... indicates that the provision for advertisement expense is not ad hoc in nature. Instead, the provision amount has been created on the basis of the abovementioned details and is in respect of an ascertained liability. The same were not submitted with the Ld. AO as it were not called for by the Ld. AO during the course of assessment proceedings. These have also been submitted in the application dated 10 April 2014 (Refer Page 58 to 58 of the DRP submission). 39. The ld.counsel for the assessee further contended that after passing of the order by the DRP rectification application was also been filed to the DRP pointing out incorrect finding of the DRP that no details have been furnished by the assessee with regard to the provision for advertisement expenses and the same being on adhoc basis. Our attention was drawn to the rectification application submitted post the DRP direction placed before us at PB page no. 605 to 612. The ld.counsel for the assessee therefore contended that the disallowance has been made totally disregarding the facts and submissions made by the assessee in this regard. The ld.DR on the other hand, relied on the orders of authorities below. 40. We have consi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... moving stock. On being asked to justify and explain its claim, the assessee responded by stating that devaluation of stock had been done following the method of accounting prescribed under AS-2 for valuation of inventories requiring inventories to be valued at cost or net realizable value, whichever is lower, which practice the assessee had been consistently following in the past also, and which was in accordance the provisions of section 145A of the Act also. The AO however was not satisfied with the reply of the assessee for the reason that, he noted, while the assessee had reduced the value of cost of inventory by almost 50%, but had not supported this reduction in value with any evidence or logic. The AO noted that the assessee was manufacturer of hydraulic and pneumatic equipments and parts, and these items did not get decayed easily. The AO held that devaluation in accordance with the AS-2 was to be done on inventory only, in case they were damaged or had become whole or partially obsolete or their selling price has declined and the assessee has failed to prove with evidence that they became obsolete, damaged or declined in selling price of inventories so devalued by it. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... even from non moving items, that the realizable value of the closing stock was much more than the cost of item sold. From the profit earned on sale of spare parts it is clear that the sale price of items sold are not less than the cost price. There appears to be no justification for declaring the value of closing stock at 50% of the cost when the assessee himself has earned profit on each and every item sold. From the details of purchase, sales, opening stock and closing stock, in quantity and in value, it is proved beyond doubt that the realizable value of closing stock has not been reduced on any counts as per AS-2. From the details of sales and considering the gross profit margin on the sold items, it is clear that neither the selling price nor realizable value has declined. 2.3. Further, the assessee was requested to furnish the details of devalued items shown in opening stock and sold during the month of April, May, November & December, 2009 to find out whether the devalued items, either purchased during the year or during the earlier years have been sold at devalued price or purchase price or even more than that to find out whether the assessee has shown the correct valuat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rescribed accounting standards and complied with the provision of section 145A of the Act in this regard also; iii) That devaluation of the inventory was done by a team of technical experts of the assessee-company in accordance with a system devised noting the reduction in value of stock on account of various factors and devising a method of devaluation on age-wise analysis of the assets; iv) Complete details of all the stocks so valued along with basis of devaluation was furnished to the authorities below; v) That in view of the fact the assessee had devalued the assets as per a scientifically devised system for reduction on account of passage of time, it was in accordance with the accounting standard (AS) prescribed in this regard by the ICAI was in compliance with section 145A also and complete details were also furnished to the authorities below and the devaluation had been certified by the statutory auditors also. There was no reason for making any disallowance of devaluation which was in accordance with law. 46. In this regard, our attention was drawn to the following: * Annual accounts of the company mentioning write off slow moving stock from inventory to the exten ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ils and explanation also furnished before the lower authorities (placed before us at Page no. 617 to 620 of the PB). 47. The ld.counsel for the assessee therefore submitted that having furnished complete details and explanation regarding devaluation of the stock, and disallowance thereof was highly unjustified and needed to be deleted. 48. The ld.DR relied on the orders of the DRP/AO. 49. We have considered contentions of both the parties and gone through the orders of authorities. We have also carefully gone through all the documents referred before us. 50. On going through all the orders of the authorities below, we find that the assessee's claim of devaluation of stock to the extent of Rs. 1,79,49,564/- was disallowed primarily for the reason that the assessee was unable to file any justification for devaluation in value of stock. The DRP went to the extent of stating that claim of devaluation was not allowable to the assessee since it was earning profits on sale of spare, and there was no question of any value in the value of its stock/inventory so as to justify the devaluation. We have carefully gone through the submissions made by the assessee before the lower authorities ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... allowed u/s 36(1)(iii) of the Act since it is for the purpose of business." 53. The brief facts relating to the issue are that the AO noted that the assessee has shown capital work-in-progress at Rs. 7,29,94,068/- which included capital advance of Rs. 70,17,554/-. He further noted the assessee had incurred an amount of Rs. 59,12,913/- as interest on loans. Accordingly, he asked the assessee to explain as to why proportionate interest should not be capitalized on account of interest bearing funds having been used for acquiring capital assets which had not been put to use as per section 36(1)(iii) of the Act. The assessee responded by stating that it had not utilized any interest bearing funds for the capital WIP and entire WIP was created from its own interest free funds/WIP. The assessee also contended that accounting policy followed by the assessee in relation to borrowing cost as prescribed by the ICAI in AS-16 requiring of borrowing cost incurred for acquiring fixed assets to be capitalized was being consistently followed by the assessee which was mentioned in the audited financial statement of the assessee also. The AO however was not satisfied with the reply of the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... placed on the decision of the ITAT, Ahmedabad in the case of CIL Nova Petrochemicals Ltd. Vs. ITO, ITA No. 1401/Ahd/2017 order dated 25.3.2019. (copy of which was placed before us). 56. The ld.counsel for the assessee further pointed out that its accounting policy adopted was in accordance with AS-16 prescribed by the ICAI for accounting of borrowing cost which require borrowing cost attributable to acquisition, construction or production of a qualifying asset to be capitalized to the cost of assets and Auditors in the Notes to the Accounts forming part of the audited balance sheet had mentioned so in clear terms in Schedule-18 thereof. It was further pointed out that in the subsequent assessment year, the assessee had capitalized interest on CWIP to the extent of Rs. 2,17,80,822/- and had clearly mentioned so in its audited balance sheet; thus demonstrating that borrowing cost attributable to CWIP were being added to CWIP as mandated by AS16. Our attention as also drawn to audited report for the impugned year mentioning that no interest was disallowable under provisions of section 36(1)(iii) of the Act and also no interest expenditure of capital nature have been debited to the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve, we direct the deletion of disallowance of interest expenditure to the extent of Rs. 59,12,913/-. Ground No. 9 is allowed. Now we take up Revenue's Appeal in IT(TP) 850/Ahd/2015 for A.Y.2010-11 58. Ground no. 1 reads as under: "(i) Whether the DRP has substantially erred in deleting the addition of Rs. 60,22,515/- being provision for product support despite the fact that the assessee has made only provision in the P&L account and failed to produce any evidence to prove." 59. Issue raised by the Revenue in the above grounds relates to disallowance proposed by the AO in his draft order of provision made by the assessee for product support amounting to Rs. 60,22,515/- the objection to the same by the assessee before the DRP was accepted and the DRP accordingly directed the AO to delete the disallowance. 60. As transpires from the orders of the authorities below, the provision for product support had been debited by the assessee for after sale services/warranty/ product support and was explained by the assessee to have been calculated by adopting scientific method, by calculating average proportion of actual warranty cost to total sales for past three years. This percentage w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der fof CIT(A) for A.Y 2006-07 " Similar issue in earlier years has been decided in favour of the appellant by CIT (A) as well as IT A T in the appellants own case. The claims have been made on the basis of pending warrant claims received from branched at the close of the year. It is also seen that in earlier years, the CIT(A) have deleted such addition on the basis of the order of IT AT in appellants own case. Therefore, following the order of IT AT ant my predecessors, the addition made by the AO is deleted" Following the earlier years order of Tribunal in the assessee's own case, we allow this ground of objection and direct the AO to delete the disallowance." 62. Therefore noting the facts that the issue stood decided in favour of the assessee by the ITAT in the earlier years, the DRP agreed to the objection of the assessee to the disallowance made by the AO for provision for products support/services, and accordingly, the DRP directed the AO to delete the disallowance so made. 63. Before us, the ld.DR was unable to point out any infirmity in the order of the ld.CIT(A). The ld.DR was also unable to distinguish the earlier year case of the assessee with the present one. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Information Technology Support Charges 56,32,518 allowed Total 6,16,78,335 66. The TPO analyzed all the material before him regarding these intra-group services and held that the services rendered by the AEs with regard to template charges and infrastructure consultancy charges were only in the nature of stewardship services necessary for overseeing the function undertaken by the assessee for the benefit of AE and not giving any benefit directly to the assessee. He noted that they were only in the nature of control and supervisory function of the providers of the services, and therefore, treated that the ALP of these services provided to the assessee by the AE at NIL. The assessee's explanation and the TPO's finding in this regard summarized in a table produced at page no. 3 to 5 of the DRP's order as under: Sr. No. Assessee's function as per their Transfer Pricing Study Report Description given by the assesses Analysis of the documents Supplied and remarks Amount involved and remarks 1 Licensed Manufacturer with less than normal risk and distributor in respect of trading functions RAINBOW- From a strategic realignment to RAINBOW: In order to achieve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... DRP held that they were not in the nature stewardship services, but to the direct benefit to the assessee, and accordingly deleted the adjustment proposed by the AO/TPO for the services at NIL on both counts. 68. Taking up the first explanation of the assessee regarding template charges, the assessee contended that the charges related to cost of procuring SAP licence and customizing the same as per the needs of the group's business. It was explained that on behalf of the assessee, the Bosch Rexroth AG had purchased the SAP license from third party and carried out the relevant customization to ensure that the SAP modules met with the business requirement of the Bosch entities; that for drives and control ("DC") business, this customized SAP was named "Rexroth Application Integration for Business Optimization Worldwide" ("Rainbow"); that for every DC units in the Bosch group, SAP template was provided by Rexroth and charges were based on users. Accordingly, the assessee being a part of the drive and control business of the Bosch group, had acquired the above Rainbow template from Rexroth AG. It was contended that the template charges paid by the assessee to its AE was on account of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re. In our view pricing of the software can not be nil, unless it is held that no software was actually procured. We have already held that there is nothing on the record to hold that no software was actually procured by the assessee. Hence the adjustment proposed by the TPO by treating ALP of the Rainbow Template at NIL is unjustified. The TPO is also of the view that the provision of software by the AE amounts to controlling and supervisory activity. We find it a rather stretched inference not supported by facts. The software was developed as claimed by the assessee and not refuted by the TPO, to smoothen flow of information and increase connectivity among the group concerns. The assessee has lot of transactions with the group concerns and ail such transactions have been accepted by the TPO as at ALP. A software to streamline arms length business transactions and increase connectivity with other group concerns cannot be called per se a device by the AE to tighten its control over the assesee's affairs and that also to the detriment of the assessee. We therefore direct the AO/TPO to delete this adjustment." 70. The ld.DR before us has been unable to controvert the fact demons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity at Sanand, Ahmedabad. The facility is constructed based on the standards prescribed by the Bosch Group and with guidance on the infrastructural development from the Group. Since this amount represents recovery of cost (without any mark up) the transaction value is not inconsistent with the arm's length standard as provided /s. under section 92C of the Income-tax Act, 1961." 72. The DRP, we have noted, went on to note that the TPO did not dispute the above facts that the infrastructure consultancy and support services offered by the AE to the assessee, was for development of additional infrastructure facility of the assessee by way of setting up of new plant at Sanand. Since the TPO had held this service also in the nature of stewardship services, the DRP disagreed with the finding of the TPO proposing determination of ALP of the said services at NIL. The relevant finding of the DRP at para 4.1 and 4.2 of the order is as under: "4.1 The TPO has not disputed the facts but has held that the The AE provided services to make certain that the various offices maintained AE's production standards and that the subsidiaries performed their duties to their clients' satisfac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rk in progress during the year under consideration and had not claimed depreciation on it. It is therefore prayed that in the event if the objection of the AO is upheld, the Ld. AO be directed not to adjust the payment made by the Cross objector on account of international transaction of Infrastructure Consultancy and Support services as the international transaction has no impact on the profit and loss account for the year under consideration." 78. As is evident from the bare perusal of the above grounds, the plea of the assessee before us is two folds, viz. (i) that with respect to TP adjustment made on account of payment of template charges paid to AE of the assessee amounting to Rs. 2,91,40,800/- treating the ALP of the same as NIL by the TPO, since the assessee had treated the amounts so paid as capital expenditure and claimed only depreciation on the same, therefore, the adjustment to be made to the income of the assessee on account of determination of ALP of the impugned transactions is to be restricted to claim of depreciation only; (ii) that with respect to TP adjustment made to international transaction of infrastructure consultancy and support services amounting to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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