https://www.taxtmi.com/caselaws?id=192187 In determining ALP for the assessee's international transaction, the ITAT held that working capital differences materially affect comparability and directed the AO/TPO to grant an appropriate working capital adjustment, resulting in recomputation of the transfer pricing adjustment. However, it rejected any risk adjustment because the assessee failed to objectively quantify risk differentials, so no such adjustment was permissible. On depreciation, the ITAT treated computer peripherals as part of the computer system and, following binding precedent, allowed depreciation at 60%, overturning the lower authority's restriction as office equipment. Levy of interest under s.234B was held to be consequential. The appeal was partly allowed. en-us Fri, 27 Sep 2013 00:00:00 +0530 Wed, 31 Dec 2025 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192187 In determining ALP for the assessee's international transaction, the ITAT held that working capital differences materially affect comparability and directed the AO/TPO to grant an appropriate working capital adjustment, resulting in recomputation of the transfer pricing adjustment. However, it rejected any risk adjustment because the assessee failed to objectively quantify risk differentials, so no such adjustment was permissible. On depreciation, the ITAT treated computer peripherals as part of the computer system and, following binding precedent, allowed depreciation at 60%, overturning the lower authority's restriction as office equipment. Levy of interest under s.234B was held to be consequential. The appeal was partly allowed. Case-Laws Income Tax Fri, 27 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192187