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4.2 On the facts and in the circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP erred in disregarding the fact that the royalty transaction is closely linked and inter- related with the other international transactions of the Appellant. 4.3 On the facts and in the circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP erred in not considering the entity level benchmarking analysis carried out by the Appellant under the TNMM to justify the royalty transaction. 4.4 On the facts and in the circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP erred in disregarding the analysis carried out under the comparable uncontrolled price method and submitted by the Appellant on a without prejudice basis. 4.5 Without prejudice to the other ground of appeal, on the facts and in the circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP, erred in not appreciating that transaction of royalty cannot be benchmarked using the profit split method.

6. The lower authorities, ought to have noticed that the above methodology meets the provisions laid down in Rule 10AB of the Income-tax Rules, 1962, read with section 92C(1)(f) of the Income-tax Act, 1961, and is the most appropriate method in the present facts, also being retrospective in operation and hence applicable to the year under consideration.

7. The lower authorities, erred in not noticing that the above methodology also broadly corresponds with the provisions laid down in second proviso to Rule 10B(1)(d) of the Income-tax Rules, 1962, relating to Profit Split Method.

4. The lower authorities, erred in not noticing that the above methodology also broadly corresponds with the provisions laid down in second proviso to Rule 10B(1)(d) of the Income-tax Rules, 1962, relating to Profit Split Method.

5. The lower authorities, erred in not noticing that the above methodology is also in accordance with Paragraph 6.139 of the revised 2015 OECD transfer pricing guidelines, and Paragraph 13 of the 1979 OECD transfer pricing guidelines.