The Transfer Pricing Officer aggregated the assessee’s payment of royalty with other manufacturing transactions for determining the arm’s length price. The Tribunal held that payment of royalty for use of technical know-how was an independent international transaction and could not be aggregated with manufacturing activities merely because the technology was used in the manufacturing process. Since the royalty charged by the associated enterprise from another independent party for the same product was higher than that charged from the assessee, the royalty paid by the assessee was held to be at arm’s length, and the adjustment was deleted. (AY. 2018-19).