https://www.taxtmi.com/caselaws?id=234877 The Tribunal ruled in favor of the Assessee on all counts. It held that the royalty payment was at arm's length, the royalty was a revenue expenditure, UPS was eligible for higher depreciation, and the loss on foreign exchange forward covers was a business expense. The Tribunal found that the Transfer Pricing Officer's determination of the arm's length price of royalty paid to an associated enterprise at 'nil' was flawed, and no adjustment was required. The Tribunal also disagreed with the Assessing Officer's treatment of the royalty payment as capital expenditure, determining it to be a revenue expenditure. en-us Fri, 21 Jun 2013 00:00:00 +0530 Sat, 02 Apr 2016 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234877 The Tribunal ruled in favor of the Assessee on all counts. It held that the royalty payment was at arm's length, the royalty was a revenue expenditure, UPS was eligible for higher depreciation, and the loss on foreign exchange forward covers was a business expense. The Tribunal found that the Transfer Pricing Officer's determination of the arm's length price of royalty paid to an associated enterprise at 'nil' was flawed, and no adjustment was required. The Tribunal also disagreed with the Assessing Officer's treatment of the royalty payment as capital expenditure, determining it to be a revenue expenditure. Case-Laws Income Tax Fri, 21 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234877