Court Rules FMS Payments Must Be Separately Benchmarked in TP Cases; No Offsetting with Other Transactions' Income.

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....TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the international transactions may be grabbed by the income from another international transaction giving higher income on transacted value - accordingly, international transaction of payment of FMS cannot be clubbed with other international transactions for showing the same at ALP - It needs to be benchmarked separately....