https://www.taxtmi.com/caselaws?id=358390 Where reliable internal comparables were available, export of trucks to associated enterprises was benchmarked transaction-wise under internal TNMM rather than by aggregating segments and applying external TNMM; the domestic segment was accepted as the proper benchmark. Import of raw materials/components from associated enterprises was treated as a separate transaction, and the matter was remitted for fresh arm's length price examination because the assessee had changed its stand and relied on additional evidence requiring verification. Any transfer pricing adjustment was confined to the international transactions actually under review, and entity-level adjustment was rejected. en-us Tue, 03 Apr 2018 00:00:00 +0530 Wed, 11 Apr 2018 08:02:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358390 Where reliable internal comparables were available, export of trucks to associated enterprises was benchmarked transaction-wise under internal TNMM rather than by aggregating segments and applying external TNMM; the domestic segment was accepted as the proper benchmark. Import of raw materials/components from associated enterprises was treated as a separate transaction, and the matter was remitted for fresh arm's length price examination because the assessee had changed its stand and relied on additional evidence requiring verification. Any transfer pricing adjustment was confined to the international transactions actually under review, and entity-level adjustment was rejected. Case-Laws Income Tax Tue, 03 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358390