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2017 (11) TMI 1806 - SCH - Income TaxTransfer pricing adjustment - bench marking - royalty and technical assistance fee did not form part of a composite transaction and have to be treated as two separate transactions for the purpose of benchmarking and computing arms length price - transactional Net Margin Method applied for benchmarking/computing arm's length price in respect of transaction relating to "technical assistance fee - HELD THAT:- SLP dismissed.
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