Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation  of arms length price — ALP of royalty payment was determined at NIL by TPO without following any of the prescribed method on purely ad hoc basis without assigning any reasons is not sustainable. mechanism prescribed under section 10B(1)(a) not being discernible from the order of TPO it could not be said that ALP was determined by application of CUP method; rate at which payment of royalty was approved by RBI can be considered as ALP — Assistant Commissioner of income tax vs. Netafim Irrigation India P. Ltd. [2019] 202 TTJ (Mumbai) 1019