Companies Excluded from Transfer Pricing: Excessive Related Party Transactions; 25% Depreciation for Intangibles Upheld by Tribunal.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP Adjustment made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.....