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Transfer Pricing Adjustment: Apply CUP Method for Royalties to AEs, Validated by RBI or SIA, per Rule 10B(1)(a).
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....TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid....