Court Rules Against Isolating Fee Payments for Transfer Pricing; Consistency Required in Benchmarking Method.

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....Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM - Different method (CUP method) for royalty and technical knowhow - it was not open to the TPO to subject only one element, i.e. payment of technical assistance fee, to an entirely different method (CUP)....