https://www.taxtmi.com/caselaws?id=766484 The royalty transfer pricing dispute concerned whether the arm's length price for payments to a non-UK associated enterprise could be rejected despite CUP benchmarking, TNMM corroboration, and support from comparable group agreements. The record indicated that the UK and non-UK licences were substantively similar, no material product difference justified a different royalty rate, and the adjustment relied on a single comparable with an ad hoc further reduction lacking factual basis. MAP settlement for the same assessee and a later APA covering identical royalty transactions were treated as persuasive, and consistency was applied because no material change in facts was shown. The adjustment was therefore unsustainable and the royalty was accepted under the APA and MAP parameters. en-us Fri, 21 Feb 2025 00:00:00 +0530 Fri, 03 Apr 2026 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766484 The royalty transfer pricing dispute concerned whether the arm's length price for payments to a non-UK associated enterprise could be rejected despite CUP benchmarking, TNMM corroboration, and support from comparable group agreements. The record indicated that the UK and non-UK licences were substantively similar, no material product difference justified a different royalty rate, and the adjustment relied on a single comparable with an ad hoc further reduction lacking factual basis. MAP settlement for the same assessee and a later APA covering identical royalty transactions were treated as persuasive, and consistency was applied because no material change in facts was shown. The adjustment was therefore unsustainable and the royalty was accepted under the APA and MAP parameters. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766484