Capitalized Expense shouldn’t be considered for computation of proportionate TP adjustment

Toyota Industries Engine India Pvt Ltd Vs NFAC (ITAT Bangalore) ITAT Bangalore held that as professional and consultation charges & purchase of fixed assets are capitalized in the books of accounts, it should not be considered for computation of proportionate TP adjustment. Facts- This appeal by assessee is directed against final assessment order passed by AO / NFAC for the assessment year 2016-17. It mainly contested that AO has erred in computation of proportionate adjustment by including the two international transactions which are capital in nature i.e. Payment of professional and cons...