https://www.taxtmi.com/caselaws?id=333481 The HC held that the TNMM for ALP determination requires accurate and relevant segmental data on costs, sales, and assets employed to assess comparables' profitability. The revenue's claim that segmental data was available was rejected, as mere turnover proportions for software product sales do not suffice to establish relevant segmental data. The court emphasized that transfer pricing methodologies aim to identify taxable income within jurisdictional limits and differ from domestic income assessments. The decision underscored the necessity of appropriate transactional filters and detailed data to apply TNMM correctly, leading to the conclusion that the revenue's adjustment lacked a proper basis due to insufficient segmental information. en-us Wed, 28 Sep 2016 00:00:00 +0530 Tue, 05 May 2026 13:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=333481 The HC held that the TNMM for ALP determination requires accurate and relevant segmental data on costs, sales, and assets employed to assess comparables' profitability. The revenue's claim that segmental data was available was rejected, as mere turnover proportions for software product sales do not suffice to establish relevant segmental data. The court emphasized that transfer pricing methodologies aim to identify taxable income within jurisdictional limits and differ from domestic income assessments. The decision underscored the necessity of appropriate transactional filters and detailed data to apply TNMM correctly, leading to the conclusion that the revenue's adjustment lacked a proper basis due to insufficient segmental information. Case-Laws Income Tax Wed, 28 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=333481