As the international transactions of payment of royalty and fees ...

Royalty and technical service payments must be assessed separately for Arm's Length Price; cannot merge under TNMM.

June 28, 2016

Case Laws Income Tax AT

As the international transactions of payment of royalty and fees for technical services are separate transactions and not closely linked with the other transactions with which the assessee has merged them, we cannot permit such merger or aggregation for the purpose of the determining their ALP on entity level under TNMM - AT

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As the international transactions of payment of royalty and fees ...

Royalty and technical service payments must be assessed separately for Arm's Length Price; cannot merge under TNMM.

June 28, 2016

Case Laws Income Tax AT

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