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TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
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International Tax
TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
Posted on
on
May 31, 2017
Tenet Tax Daily May 31 2017
By
tenettax-team
International Tax
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Matter remanded by Tribunal as TPO rejected CUP method applied by assessee without assigning any reason
TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
