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The ITAT accepted that the assessee's trading activity and customer service functions formed an integrated business model, so separate carving out of a trading segment for transfer pricing was not justified. Following its decision in the assessee's own case for the immediately preceding year, the Tribunal held that the transaction profile was identical and that the Transfer Pricing Officer's segmentation approach could not be sustained. It therefore accepted the assessee's claim for application of the Transactional Net Margin Method at entity level and rejected separate benchmarking of the trading activity.
The ITAT accepted that the assessee's trading activity and customer service functions formed an integrated business model, so separate carving out of a trading segment for transfer pricing was not justified. Following its decision in the assessee's own case for the immediately preceding year, the Tribunal held that the transaction profile was identical and that the Transfer Pricing Officer's segmentation approach could not be sustained. It therefore accepted the assessee's claim for application of the Transactional Net Margin Method at entity level and rejected separate benchmarking of the trading activity.
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