https://www.taxtmi.com/caselaws?id=795332 Transfer-pricing analysis of royalty and associated-enterprise service payments should recognise documented business need and benefits; payments cannot be disallowed solely through a subjective assessment of benefit. Where an Advance Pricing Agreement covers identical transactions in later years and there is no demonstrated change in functions, assets, risks, or transaction nature, its agreed methodology and margins may guide arm's-length determination for earlier years, despite not formally applying to them. The royalty adjustment was confined to the excess over the agreement-based arm's-length benchmark, and the restricted transfer-pricing adjustments were sustained. en-us Tue, 16 Jun 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795332 Transfer-pricing analysis of royalty and associated-enterprise service payments should recognise documented business need and benefits; payments cannot be disallowed solely through a subjective assessment of benefit. Where an Advance Pricing Agreement covers identical transactions in later years and there is no demonstrated change in functions, assets, risks, or transaction nature, its agreed methodology and margins may guide arm's-length determination for earlier years, despite not formally applying to them. The royalty adjustment was confined to the excess over the agreement-based arm's-length benchmark, and the restricted transfer-pricing adjustments were sustained. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795332