Segmental aggregation under TNMM prevents a separate nil arm's...

Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded from routine service-provider benchmarks. TDS credit must be allowed, interest under section 234A is not leviable on the stated facts, and consequential tax computation is required.