Royalty paid as per Govt/RBI approval will be treated as at arm’s length

Dow Agrosciences India Private Limited Vs ACIT (ITAT Mumbai) We shall now deal with the observation of the TPO/DRP that the approval provided by the RBI would not constitute a valid CUP data, since the RBI does not take into account the transfer pricing provisions to determine the appropriate rates which can be considered as the arm‟s length price for the As observed by us hereinabove, royalty paid by the assessee had been approved by the Secretariat of Industrial approval, Ministry of Industry (Government of India) and RBI, vide their approvals, dated 17th September, 1996 and 22nd January, ...