Tagged “fees-for-technical-services”

Bellsonica Auto Component India v. ACIT (2026): a transfer-pricing royalty adjustment must be capped at the rate the CBDT accepted under the assessee's APA

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.