Held that the requisite details were submitted and the authorities below had failed to consider them and instead held that proper details were not submitted after having held that there was no benefit to the assessee from the licence That the authorities below had erred in holding the arm’s length price at nil on the ground that relevant documents had not been submitted. The details as regards the issue of cost sharing had been submitted and the authorities below had erred in ignoring them. The assessee had discharged the onus cast upon it. The determination of arm’s length price at nil without following one of the methods prescribed under section 92C of the Income-tax Act, 1961, read with rule 10B of the Income-tax Rules, 1962, was not sustainable. (AY.2008-09)