https://www.taxtmi.com/caselaws?id=461284 The ITAT Bangalore upheld depreciation adjustments for transfer pricing purposes, following precedent from the assessee's own case for A.Y. 2004-05 and Mumbai Tribunal's decision in Pangea 3 Legal Database Systems. The tribunal allowed exclusion of six comparable companies as functionally dissimilar and confirmed application of turnover filters. Regarding risk adjustment, while agreeing with the principle under Rule 10D, the tribunal modified CIT(A)'s directions by requiring the assessee to provide comprehensive information to AO/TPO for computing risk differentials between the assessee and comparables to determine appropriate adjustments. en-us Thu, 30 Jun 2022 00:00:00 +0530 Wed, 26 Mar 2025 15:47:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461284 The ITAT Bangalore upheld depreciation adjustments for transfer pricing purposes, following precedent from the assessee's own case for A.Y. 2004-05 and Mumbai Tribunal's decision in Pangea 3 Legal Database Systems. The tribunal allowed exclusion of six comparable companies as functionally dissimilar and confirmed application of turnover filters. Regarding risk adjustment, while agreeing with the principle under Rule 10D, the tribunal modified CIT(A)'s directions by requiring the assessee to provide comprehensive information to AO/TPO for computing risk differentials between the assessee and comparables to determine appropriate adjustments. Case-Laws Income Tax Thu, 30 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461284