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The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
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