https://www.taxtmi.com/highlights?id=100921 A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential. en-us Fri, 19 Jun 2026 08:24:43 +0530 Fri, 19 Jun 2026 08:24:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100921 A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential. Highlights Income Tax Fri, 19 Jun 2026 08:24:43 +0530 https://www.taxtmi.com/highlights?id=100921