Held that the Assessee has compared the price which has been charged for the same and similar uncontrolled transaction carried out with non-AEs under similar circumstances with the price charged from its AEs in the benchmarking methodology adopted by it, there was no justifiable reason for rejection of the transfer pricing study report prepared by the assessee; since there is no evidence that assessee has charged surcharge to non-AEs higher than what is chargeable to AEs, the AO is directed to delete the adjustment made by adopting TNMM. (AY. 2021-22)
Ebix Travels (P) Ltd. v. DCIT (2025) 237 TTJ 751/ 178 taxmann.com 68 (Bang)(Trib)
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Surcharge on sale of air tickets to AEs-There is no evidence that assessee has charged a surcharge to non-AEs higher than what is chargeable to AEs-The AO is directed to delete the adjustment made to the ALP of the international transaction of sale of air tickets. [S.92CA]
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