https://www.taxtmi.com/caselaws?id=472191 Royalty paid for technical know-how used in manufacturing should be benchmarked under the Transactional Net Margin Method where the foreign associated enterprise only provides technology and does not undertake manufacturing or sales functions. The Profit Split Method requires both associated enterprises to contribute to profits from the relevant transaction and is generally unsuitable without a unique and valuable contribution by the technology provider alongside the manufacturer. On materially similar prior-year and group-company facts, the Transactional Net Margin Method is the most appropriate method; the arm's length price requires recomputation after the taxpayer receives an opportunity of hearing. en-us Mon, 26 Sep 2022 00:00:00 +0530 Thu, 01 Oct 2026 18:10:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472191 Royalty paid for technical know-how used in manufacturing should be benchmarked under the Transactional Net Margin Method where the foreign associated enterprise only provides technology and does not undertake manufacturing or sales functions. The Profit Split Method requires both associated enterprises to contribute to profits from the relevant transaction and is generally unsuitable without a unique and valuable contribution by the technology provider alongside the manufacturer. On materially similar prior-year and group-company facts, the Transactional Net Margin Method is the most appropriate method; the arm's length price requires recomputation after the taxpayer receives an opportunity of hearing. Case-Laws Income Tax Mon, 26 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472191