1      Introduction

In the preceding blog post, we examined some important aspects concerning depreciation allowance in context of the transactional net margin method (TNMM) and key Indian transfer pricing decisions wherein the Income Tax Appellate Tribunal (ITAT) recognized the necessity of either making appropriate adjustments or altogether disregarding depreciation allowance in case of significant differences between a tested party and comparables. In this blog post on the topic, we would take a look at some important Indian transfer pricing decisions wherein it was held that depreciation could not be disregarded while determining the arm’s length price (ALP) in case of asset-intensive industries such as manufacturing enterprises.