https://www.taxtmi.com/caselaws?id=793601 Transfer pricing adjustment for royalty and technical fees was examined against the arm's length price methodology. The Tribunal found the later unilateral APA, under which a consolidated 1.9% of net sales was accepted for royalty and fees for technical services, persuasive for the year under appeal. On that basis, the excessive adjustment was not sustained and the APA rate was taken as the guiding benchmark, restricting the arm's length determination for those payments. en-us Wed, 17 Jun 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793601 Transfer pricing adjustment for royalty and technical fees was examined against the arm's length price methodology. The Tribunal found the later unilateral APA, under which a consolidated 1.9% of net sales was accepted for royalty and fees for technical services, persuasive for the year under appeal. On that basis, the excessive adjustment was not sustained and the APA rate was taken as the guiding benchmark, restricting the arm's length determination for those payments. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793601