Recomputing Asset Values for Transfer Pricing: Depreciation Must Reflect Revised Values, Not Affecting Capital Adjustments.

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....TPA - Capital assets - The application of the ALP, if required, will give rise to the recomputation of the revised value of the purchase of fixed assets. Such an increase in the value of the fixed assets, being a capital transaction in itself, will not give rise to any addition towards transfer pricing adjustment, but the depreciation on such assets, being a revenue offshoot of the capital transaction, will be required to be recomputed on such revised value. - AT....