https://www.taxtmi.com/highlights?id=98657 Sections 92 to 92F operate as a self-contained code for arm's length price determination, so RBI or Government approvals for royalty rates do not create any presumption for income-tax purposes. The Court accepted that the assessee's comparability analysis was inadequate and that arm's length pricing required a detailed functional and economic examination, not a bare comparison of royalty percentages. The Tribunal's fixation of royalty at 1% of export sales was treated as a factual finding, with no perversity shown, and the disallowance of excess royalty was upheld. The assessee's acceptance of 1% in later assessment years was only an additional circumstance, not the principal basis of decision, and no substantial question of law arose under Section 260A. en-us Fri, 10 Apr 2026 09:00:44 +0530 Fri, 10 Apr 2026 09:00:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98657 Sections 92 to 92F operate as a self-contained code for arm's length price determination, so RBI or Government approvals for royalty rates do not create any presumption for income-tax purposes. The Court accepted that the assessee's comparability analysis was inadequate and that arm's length pricing required a detailed functional and economic examination, not a bare comparison of royalty percentages. The Tribunal's fixation of royalty at 1% of export sales was treated as a factual finding, with no perversity shown, and the disallowance of excess royalty was upheld. The assessee's acceptance of 1% in later assessment years was only an additional circumstance, not the principal basis of decision, and no substantial question of law arose under Section 260A. Highlights Income Tax Fri, 10 Apr 2026 09:00:44 +0530 https://www.taxtmi.com/highlights?id=98657