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Royalty Payments Should Not Be Separately Analyzed; TNMM Applies to All Transactions, Including Royalties, Says Transfer Pricing Review.
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....ALP - Once TNMM has been applied to the assessee company's transaction, it covers under its ambit the Royalty transactions in question too and hence separate analysis and consequent deletion of the Royalty payments by the TPO in the instant case seems erroneous - AT....