https://www.taxtmi.com/caselaws?id=789587 Transfer pricing requires arm's length price to be determined independently on the facts of each year, and regulatory approvals under RBI or Government schemes do not by themselves establish the income-tax position because they only indicate permissible ceilings. On the facts, the authorities' view that 1% royalty on export sales represented arm's length price was upheld, as the assessee's comparables and commercial justification were found insufficient. Subsequent acceptance of the same royalty rate in later years was treated only as corroborative and not as the sole basis for the decision. No substantial question of law arose and the appeals were dismissed. en-us Thu, 26 Mar 2026 00:00:00 +0530 Fri, 10 Apr 2026 09:00:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789587 Transfer pricing requires arm's length price to be determined independently on the facts of each year, and regulatory approvals under RBI or Government schemes do not by themselves establish the income-tax position because they only indicate permissible ceilings. On the facts, the authorities' view that 1% royalty on export sales represented arm's length price was upheld, as the assessee's comparables and commercial justification were found insufficient. Subsequent acceptance of the same royalty rate in later years was treated only as corroborative and not as the sole basis for the decision. No substantial question of law arose and the appeals were dismissed. Case-Laws Income Tax Thu, 26 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789587