https://www.taxtmi.com/caselaws?id=203326 Transfer pricing analysis should focus on international transactions rather than entity-level business results where segmental accounts distinguish associated-enterprise and non-associated-enterprise dealings. Audited segmental evidence submitted to address authentication concerns is relevant for consideration in objections proceedings. Comparable-company selection may include a loss-making company where directed in the transfer pricing review. The statutory tolerance margin for arm's length pricing is described as an assessee option, reflecting that arm's length price is an approximation; its application may affect recomputation of the transfer pricing adjustment. en-us Fri, 25 Feb 2011 00:00:00 +0530 Wed, 22 May 2013 17:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203326 Transfer pricing analysis should focus on international transactions rather than entity-level business results where segmental accounts distinguish associated-enterprise and non-associated-enterprise dealings. Audited segmental evidence submitted to address authentication concerns is relevant for consideration in objections proceedings. Comparable-company selection may include a loss-making company where directed in the transfer pricing review. The statutory tolerance margin for arm's length pricing is described as an assessee option, reflecting that arm's length price is an approximation; its application may affect recomputation of the transfer pricing adjustment. Case-Laws Income Tax Fri, 25 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203326