TMI BlogAs the international transactions of payment of royalty and fees for technical services are separate...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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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