https://www.taxtmi.com/caselaws?id=308168 Royalty and management fee payments, having a close nexus with the assessee's other international transactions, were held not to require separate benchmarking. The transfer pricing study adopted by the assessee had already been accepted, and the transactions were treated as forming part of an integrated entity-level arrangement. Accordingly, aggregation with the remaining international transactions was required to determine the arm's length result by applying TNMM at entity level. The matter was remanded to the TPO and the Assessing Officer for such aggregation and benchmarking. en-us Wed, 21 Jun 2017 00:00:00 +0530 Mon, 05 Jun 2023 21:38:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308168 Royalty and management fee payments, having a close nexus with the assessee's other international transactions, were held not to require separate benchmarking. The transfer pricing study adopted by the assessee had already been accepted, and the transactions were treated as forming part of an integrated entity-level arrangement. Accordingly, aggregation with the remaining international transactions was required to determine the arm's length result by applying TNMM at entity level. The matter was remanded to the TPO and the Assessing Officer for such aggregation and benchmarking. Case-Laws Income Tax Wed, 21 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308168