https://www.taxtmi.com/highlights?id=103770 Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted. en-us Tue, 15 Sep 2026 08:31:15 +0530 Tue, 15 Sep 2026 08:31:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103770 Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted. Highlights Income Tax Tue, 15 Sep 2026 08:31:15 +0530 https://www.taxtmi.com/highlights?id=103770