https://www.taxtmi.com/caselaws?id=214068 ITAT Mumbai upheld the TPO's selection and exclusion of comparables for determining ALP in transfer pricing, affirming the exclusion of companies with dissimilar functions, capital intensity, or revenue profiles. The AO was directed to compute the profit ratio using the arithmetic mean of the approved comparables. Depreciation on UPS was held at 15%, as UPS is not integral to the computer system. The claim for interest under Section 234C was rejected due to no shortfall in advance tax payments. The decision was against the assessee on depreciation but favorable regarding interest liability and comparable selection. en-us Fri, 11 May 2012 00:00:00 +0530 Mon, 10 Aug 2026 15:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214068 ITAT Mumbai upheld the TPO's selection and exclusion of comparables for determining ALP in transfer pricing, affirming the exclusion of companies with dissimilar functions, capital intensity, or revenue profiles. The AO was directed to compute the profit ratio using the arithmetic mean of the approved comparables. Depreciation on UPS was held at 15%, as UPS is not integral to the computer system. The claim for interest under Section 234C was rejected due to no shortfall in advance tax payments. The decision was against the assessee on depreciation but favorable regarding interest liability and comparable selection. Case-Laws Income Tax Fri, 11 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214068