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Siemens Healthcare Diagnostics vs. ACIT (ITAT Ahmedabad)

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COURT:
CORAM: ,
SECTION(S):
GENRE:
CATCH WORDS: ,
COUNSEL:
DATE: September 19, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
FILE: Click here to download the file in pdf format
CITATION:
Transfer Pricing adjustment for depreciation has to be made

if the methods of depreciation adopted by the two companies are different, then the net margins arrived at are not strictly comparable unless suitable adjustment is made in the amount of depreciation so as to adopt depreciation under the same method in the two cases. Therefore, the Transfer Pricing Officer is directed to take into consideration the difference in the method of providing depreciation in the case of the assessee and the chosen comparable case and if the methods are different, then to make suitable adjustment for the same as per law

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