The ITAT Delhi held that where the CBDT has accepted a royalty and technical-fee rate of 1.9% of net sales under the assessee's Unilateral Advance Pricing Agreement, the Transfer Pricing Officer's higher adjustment is excessive and must be capped at the APA-accepted rate. A digest of the facts, the arm's-length question, and why a concluded APA carries persuasive weight.
In December 2025 a Division Bench of the Delhi High Court dismissed the Revenue's transfer-pricing appeal, faulting the Dispute Resolution Panel for merely endorsing the Transfer Pricing Officer's conclusions without recording its own findings. A digest of the facts, the statutory duty of the DRP under Section 144C, and why the Court found no substantial question of law.