Assessee-Company Must Justify Royalty Adjustments Under Transfer Pricing Agreement; Clubbing Transactions Without Justification is Prohibited.

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....TPA - ALP adjustment in respect of royalty payment made - In the absence of justification, clubbing other transactions is not possible. The onus always lies on the assessee-company to establish the justification for clubbing and aggregation of the transaction of payment of royalty with other transactions.- AT....