https://www.taxtmi.com/caselaws?id=205364 Closely linked trading transactions with the same FAR profile were benchmarked together under TNMM, so segmentation of the Consumer Product Division and System Product Division was held artificial and the related adjustment was deleted. Reimbursement of advertisement and sales promotion expenses received from associated enterprises was treated as operating income because it formed part of recurring business results, and exclusion of that receipt for benchmarking was rejected. For the Industrial Sales Division, contemporaneous data with limited prior-period data was accepted and no transfer pricing adjustment survived. Customs valuation was held to be irrelevant to arm's length price determination because Chapter X operates as a separate code. en-us Fri, 24 Sep 2010 00:00:00 +0530 Wed, 12 Jun 2013 10:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205364 Closely linked trading transactions with the same FAR profile were benchmarked together under TNMM, so segmentation of the Consumer Product Division and System Product Division was held artificial and the related adjustment was deleted. Reimbursement of advertisement and sales promotion expenses received from associated enterprises was treated as operating income because it formed part of recurring business results, and exclusion of that receipt for benchmarking was rejected. For the Industrial Sales Division, contemporaneous data with limited prior-period data was accepted and no transfer pricing adjustment survived. Customs valuation was held to be irrelevant to arm's length price determination because Chapter X operates as a separate code. Case-Laws Income Tax Fri, 24 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205364