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of The ITAT upheld the acceptance of the internal TNMM method based on audited segmental data for transfer pricing adjustments, rejecting the Revenue's attempt to disallow the certified segmental comparison between AE and Non-AE transactions. The tribunal emphasized consistency by noting that the TPO had previously accepted the segmentation approach for the same parameters in earlier assessment years without adjustment, precluding a contrary stance in the current year. Citing precedent, the tribunal held that a factual position accepted and not challenged in prior years cannot be altered subsequently. The ITAT further found internal TNMM, supported by audited segmental accounts, to be superior to external TNMM and ruled in favor of the assessee, directing acceptance of the internal TNMM method as the most appropriate for the transfer pricing determination. The appeal was accordingly allowed.
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