Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional claims remain permissible.

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....Closely linked international transactions benchmarked together under TNMM should not be selectively segregated for separate testing where the aggregated approach has been accepted for other transactions. Intra-group service payments require evidence of services and benefits, and their arm's length price cannot be treated as nil under CUP without a comparable uncontrolled transaction. The notes also address deletion of a fixed-asset purchase mark-up adjustment through consistency with an earlier year. The dividend distribution tax treaty-rate claim was remitted pending resolution of the underlying legal issue. An additional refund claim may be raised before appellate authorities without filing a revised return, for determination of correct tax liability.....