Assessee-company entered into intellectual property agreement with its foreign AE for right to use intellectual property and know-how as regards truck engine.  It paid certain amount towards royalty to said AE and adopted Comparable Uncontrolled Price (CUP) method for benchmarking arm’s length price (ALP) of said royalty.  Assessee submitted that, as per search conducted in Royalty Stat Database, royalty paid by assessee was at ALP in view of royalty paid by comparables. The TPO rejected same doubting its authenticity and determined its ALP at Nil.  Tribunal remanded to TPO for afresh adjudication. (AY. 2010-11)