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Ground of objection 11- +/-3% tolerable range as provided in proviso to Section 92C(2) of the Act.

The Ld. TPO/ AO and the Hon'ble DRP have erred in law and in facts, in computing the arm's length price without giving benefit of +/- 3 percent under the proviso to Section 92C of the Act.

Issue 2--Grounds relating to Corporate Tax Matters Ground of objection 12 -- Depreciation on computer software The learned AO has erred in treating computer software as 'Intangible assets' eligible for depreciation at the rate of 25 percent as against treating it as 'Computers including computer software' eligible for depreciation at the rate of 60 percent as claimed by the Appellant.