directing the assessing authority/Transfer Pricing
Officer to grant depreciation charged by the
assessee in comparison to the comparable
companies after taking into consideration
corresponding ... Commissioner of Income Tax-5 & Another Vs.
M/s. Novell Software Development (India) Pvt. ltd.
5/14
7. The relevant portion of the judgment
2015
Principal Commissioner of Income Tax & Anr Vs.
M/s. Novell Software Development (India) Pvt. Ltd.,
9/14
eliminate differences in the accounting policies ... xxxx
27. Most other companies provide for
depreciation at the rates specified in the
Companies Act . The depreciation policies of a few
comparables selected
that the Assessee has a policy of
charging a higher rate of depreciation as
compared to the companies selected ... xxxx
27. Most other companies provide for
depreciation at the rates specified in the
Companies Act . The depreciation policies of a few
comparables selected
this
company for the reason that this company is
functionally similar, doing software development
services. Before us, by filing an additional
ground, the assessee seeks ... assessee also pleaded that the
mark-up computation was erroneous and needs
to include Depreciation and amortization expense
while arriving at the operating
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