Unilateral APA benchmarking guides royalty and technical-fee pricing, while omitted domestic transactions cannot sustain transfer-pricing adjustments.

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....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.....