Transfer Pricing: Royalty Payments Must Compare Controlled and Uncontrolled Transactions for Accurate Arm's Length Price Assessment.

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....TP Adjustment - payment of royalty - comparison in order to determine if the ALP cannot be done by comparing the prices charged to by A.E. which is controlled transaction, as the provisions of I.T. Act, mandates that the determination of ALP has to be done by comparison between controlled and un-controlled transactions. - AT....