Taxpayer wins: transfer pricing adjustment deleted under Section 92C; depreciation disallowance for patents and copyrights reversed

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ITAT held that the taxpayer's adoption of the "other method" was the most appropriate method for benchmarking the international sale of air tickets to an associated enterprise and, in absence of evidence that prices charged to unrelated parties exceeded those charged to related parties, directed the AO to delete the TP adjustment to the arm's-length price. ITAT further found no basis to sustain disallowance of depreciation on the opening written-down value of the patents and copyrights block where no additions occurred during the year, and directed deletion of the depreciation disallowance, allowing the taxpayer's appeal on both grounds.....