Assessee was engaged in business of distribution of its AE’s products in India through wholesale channels and retail networks for which it entered into a royalty agreement with its AE. TPO selected comparables to justify ALP of royalty at 3.31 per cent as against payment of 5 per cent royalty made by assessee. Held that a clause of guaranteed minimum royalty was present in royalty agreements of comparables selected by TPO.  Since no such clause was available in case of assessee, said comparables would be excluded and arithmetic mean of comparables would come to 5.25 per cent which was more than royalty paid by assessee. Accordingly the  royalty paid by assessee would be within arm length range and impugned ALP adjustments  were deleted  Tribunal also held that   where the  assessee purchased merchandise and samples from its AE for resale in India without any value addition, in such case, Resale Price Method (RPM) is Most Appropriate Method (MAM) to benchmark said international transaction. (AY. 2012, 13, 2013-14)