ITAT upholds 5.6% royalty rate for transfer pricing, aligning with DRP's decision; no substantial legal question found.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP adjustment - ALP of royalty - In the absence of empirical data, stating higher royalty was not justified only because it did not result in any tangible benefit to the Assessee was not be the right approach - ITAT direction to the TPO to adopt the percentage(5.6%) as has been accepted by DRP based on survey report of travel industry in subsequent year does not appear to be unreasonable - no substantial question of law arises....