According to Rule 10A(d), transactions included a number of closely linked transactions. Therefore, it is clear that if the transactions are closely linked transactions, they should be benchmarked together. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration, January, 2022 in paragraph nos. 3.9 to 3.12 deal with the valuation of taxpayer’s separate and combined transactions. This also accepts that ideally the transactions should be tested on a transaction by transaction basis. However, in certain circumstances if the transactions are closely linked or continuous that they cannot be evaluated adequately on a separate basis and when it is impracticable to determine pricing for each individual product in those circumstances, it may be more reasonable to assess the ALP for two items together rather than individually. It also considered the portfolio approaches wherein some products are marked by taxpayer with a low profit or even at a loss in portfolio. It also considers the cases where the sale of products is also part of the package deal. In those circumstances, it suggests that it is more practicable to adopt aggregate in those transactions and determine ALP on combined transaction basis.  (AY. 2005-006 to 2010-11)