https://www.taxtmi.com/caselaws?id=800738 Royalty and fees for technical services payable to an associated enterprise are benchmarked at 1.9% of net sales under the unilateral advance pricing agreement methodology, rather than nil or 2%. Omission of the provision covering expenditure with specified related parties from specified domestic transactions, effective 1 April 2017, precludes a transfer-pricing adjustment for manufacturing activity founded on that provision for the relevant assessment year. Taxable income must therefore apply the 1.9% royalty and technical-service rate and exclude the manufacturing adjustment. en-us Wed, 07 Oct 2026 00:00:00 +0530 Sat, 10 Oct 2026 08:32:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800738 Royalty and fees for technical services payable to an associated enterprise are benchmarked at 1.9% of net sales under the unilateral advance pricing agreement methodology, rather than nil or 2%. Omission of the provision covering expenditure with specified related parties from specified domestic transactions, effective 1 April 2017, precludes a transfer-pricing adjustment for manufacturing activity founded on that provision for the relevant assessment year. Taxable income must therefore apply the 1.9% royalty and technical-service rate and exclude the manufacturing adjustment. Case-Laws Income Tax Wed, 07 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800738