https://www.taxtmi.com/caselaws?id=754609 The ITAT Kolkata directed the TPO/AO to remove two comparables (Stelco Limited and Tata Steel BSL Limited) due to significant depreciation differences and functional dissimilarities with the newly set-up assessee company. The assessee's depreciation was 16.92% of revenue compared to 1.09% and 11.19% for the rejected comparables. The tribunal accepted two new comparables (Vallabh Steel Limited and Uttam Galva Steels Ltd) and directed fresh comparable search. Following precedent in Epcos Ferrites Ltd, the tribunal ruled that depreciation should be excluded from net profit margin calculations under TNMM, favoring cash PLI method for transfer pricing adjustment computation. en-us Mon, 26 Feb 2024 00:00:00 +0530 Wed, 26 Jun 2024 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754609 The ITAT Kolkata directed the TPO/AO to remove two comparables (Stelco Limited and Tata Steel BSL Limited) due to significant depreciation differences and functional dissimilarities with the newly set-up assessee company. The assessee's depreciation was 16.92% of revenue compared to 1.09% and 11.19% for the rejected comparables. The tribunal accepted two new comparables (Vallabh Steel Limited and Uttam Galva Steels Ltd) and directed fresh comparable search. Following precedent in Epcos Ferrites Ltd, the tribunal ruled that depreciation should be excluded from net profit margin calculations under TNMM, favoring cash PLI method for transfer pricing adjustment computation. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754609