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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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TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
Posted on
on
June 1, 2017
Tenet Tax Daily May 31 2017
By
tenettax-team
International Tax
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TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
TPO should assign reasons explaining differences in FAR analysis of comparable to reject them in relevant year
