https://www.taxtmi.com/article/detailed?id=6969 Aggregation for transfer pricing is permitted where multiple transactions are closely linked or arise from a common source, so that terms and pricing are determined on the totality rather than individually. Indian rules (including Rule 10A(d)) and OECD guidance allow bundling when separate evaluation is impracticable. Aggregation is limited by tests of package deal, dependency, similar functions, availability of comparables, and per-associated-enterprise boundaries; unrelated transactions or improperly convenience-aggregated packages must be benchmarked separately. en-us Wed, 07 Sep 2016 10:24:33 +0530 Wed, 07 Sep 2016 10:35:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6969 Aggregation for transfer pricing is permitted where multiple transactions are closely linked or arise from a common source, so that terms and pricing are determined on the totality rather than individually. Indian rules (including Rule 10A(d)) and OECD guidance allow bundling when separate evaluation is impracticable. Aggregation is limited by tests of package deal, dependency, similar functions, availability of comparables, and per-associated-enterprise boundaries; unrelated transactions or improperly convenience-aggregated packages must be benchmarked separately. Articles Income Tax Wed, 07 Sep 2016 10:24:33 +0530 https://www.taxtmi.com/article/detailed?id=6969