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Tribunal was justified in remanding the case back to the transfer pricing officer for the purpose of the exercise of transfer pricing analysis on the combined transaction approach and not on the different segment basis deserves to be undertaken with respect to royalty payment by assessee to its AE

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Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — Tribunal was justified in remanding the case back to the transfer pricing officer for the purpose of the exercise of transfer pricing analysis on the combined transaction approach and not on the different segment basis deserves to be undertaken with respect to royalty payment by assessee to its AE — Toyota Kirloskar Motor P. Ltd. vs. Commissionerof Income tax [2018] 305 CTR (Karnataka) 206     

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