TPO Must Include Full Costs, Adjust Depreciation Rates for Fair Margin in Software Development Segment.

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....TP Adjustment - Determination of ALP - TPO directed to consider the entire cost for the purposes of computing the margin of assessee under the software development segment as per the following directions. While computing the ALP of assessee, the depreciation as per schedule to Companies Act, is to be included as an element of operating cost. In the event, there is a difference in the rate of depreciation between the assessee vis-a-vis the comparables, suitable adjustments are to be granted in accordance with law. - AT....