https://www.taxtmi.com/caselaws?id=244566 ITAT Delhi held that for computing arm's length price under TNMM using internal comparables, only net profit margin computation is necessary with appropriate comparability adjustments. Segmental accounts need not be audited or maintained in regular books if expense allocation is reasonable. The tribunal found man-hour basis allocation fair and rejected TPO's objection to segmental accounts. Size differences between controlled and uncontrolled transactions within same entity don't render them incomparable at transaction level. Internal TNMM comparing AE and non-AE profitability was accepted. Regarding head office services addition, it was set aside following previous year's decision favoring assessee. en-us Fri, 21 Feb 2014 00:00:00 +0530 Mon, 12 May 2025 13:05:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244566 ITAT Delhi held that for computing arm's length price under TNMM using internal comparables, only net profit margin computation is necessary with appropriate comparability adjustments. Segmental accounts need not be audited or maintained in regular books if expense allocation is reasonable. The tribunal found man-hour basis allocation fair and rejected TPO's objection to segmental accounts. Size differences between controlled and uncontrolled transactions within same entity don't render them incomparable at transaction level. Internal TNMM comparing AE and non-AE profitability was accepted. Regarding head office services addition, it was set aside following previous year's decision favoring assessee. Case-Laws Income Tax Fri, 21 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244566