S. 92C : Transfer pricing-Arm’s length price-Royalty-Engaged in the business of industrial gases through plant operated with technical assistance from associated enterprise-Payments made to associated enterprise-Royal at 4% on sales to be taken as arm’s length-No contrary evidence to disregard factum of technical services rendered by associated enterprise-Computation of 1% fess by A.O. as arm’s length adhoc-Not sustainable-Matter remanded. [S. 92]