Where TNMM had been accepted as the most appropriate method, the...

Where TNMM had been accepted as the most appropriate method, the net margin was held to subsume the effect of notional interest on outstanding receivables, so no separate upward adjustment was warranted and the receivables adjustment was deleted. The arm's length rate on ECB interest was upheld at LIBOR plus 200 basis points, following the assessee's earlier years, so that adjustment was sustained. Leasehold charges were treated as proportionately amortisable over the lease term, and the disallowance of the year's claim was vacated. Royalty was held not to permit separate benchmarking once aggregated under TNMM, but the issue was remitted because the operating cost used for PLI computation did not reconcile with the books.

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