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2018 (6) TMI 36 - KARNATAKA HIGH COURTTPA - arm’s length price adjustment in respect of royalty payment - as per tribunal no necessity for benchmarking in respect of royalty transactions - Held that:- It is apparent from the impugned order that there is no discussion as regards the applicability or otherwise of the decision in case of Sony Ericsson Mobile Communications India Pvt. Ltd. (2015 (3) TMI 580 - DELHI HIGH COURT) while deciding the question of separately bench marking royalty where royalty paid was already a part of the operating cost. Further, there is strength in the assertion of the appellant as regards non-hearing on the grounds raised in the memorandum of appeal which is apparent on a bare perusal of the impugned order.- thus the matter is set aside and fit case to be remanded with a direction to decide afresh.
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