https://www.taxtmi.com/highlights?id=104780 Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed. en-us Sat, 10 Oct 2026 08:32:32 +0530 Sat, 10 Oct 2026 08:32:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104780 Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed. Highlights Income Tax Sat, 10 Oct 2026 08:32:32 +0530 https://www.taxtmi.com/highlights?id=104780