“Umbrella” of combined entity level TNMM can’t be used to benchmark separate transactions on combine

IT/ILT : Separate transactions such as sales and royalty payments under the combined umbrella of TNMM on an entity level is not permissible as it may result in "cross-subsidization", i.e., a probable addition on account of transfer pricing adjustment arising from one international transaction may be usurped by the income from the other international transaction giving higher income on transacted value. As the international transaction of royalty payment is a separate transaction and not closely