2022 (2) TMI 1500

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....aluru. For the Respondent : Smt. Shashim Kapila, Advocate. ORDER PER CHANDRA POOJARI, ACCOUNTANT MEMBER This appeal by the revenue is directed against the order dated 31.7.2019 of the CIT(Appeals)-2, Bengaluru for the assessment year 2004- 05 on the following grounds:- "a. In the facts and circumstances of the case, the Hon'ble CIT(A) has erred in granting adjustment to the taxpayer on....

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....rce Partners International (P) Ltd. [2017] 87 taxmann.com 332 (Bang. Trib.) wherein it has been held that the depreciation adjustment is to be granted whereby the rates of depreciation is different vis-à-vis the comparable companies. Further as regards whether adjustment should be made in the hands of the tested party i.e., the assessee or the comparable companies, the Mumbai Tribunal decis....