No, as far as CBM go TA should be at the top with RT. TDK is just a better film overall. In my view, TDK isn't really a straight CBM. Yeah it has Batman, carries the name and symbol, characters, etc but in the end the whole trilogy is a crime drama. SM2 was overrated IMO, you watch it now compared to ASM, ASM is a far superior film. Iron Man 1 is deserving of its rating.
As a critic myself, I don't look into RT too much when watching a film and I've enjoyed a ton of movies that have lower ratings. Take Batman Begins for example. That is my favorite Batman film and has a 85% RT which IMO should be higher. That compared to a 92% or 95% RT rating? It's not a big difference.