2022 (2) TMI 1500

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..... galuru. For the Respondent : Smt. Shashim Kapila, Advocate. ORDER PER CHANDRA POOJARI, ACCOUNTANT MEMBER This appeal by the revenue is directed against the order dated 31.7.2019 of the CIT(Appeals)-2, Bengaluru for the assessment year 2004- 05 on the following grounds:- "a. In the facts and circumstances of the case, the Hon'ble CIT(A) has erred in granting adjustment to the taxpayer o .....

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..... urce Partners International (P) Ltd. [2017] 87 taxmann.com 332 (Bang. Trib.) wherein it has been held that the depreciation adjustment is to be granted whereby the rates of depreciation is different vis-à-vis the comparable companies. Further as regards whether adjustment should be made in the hands of the tested party i.e., the assessee or the comparable companies, the Mumbai Tribunal deci .....

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