https://www.taxtmi.com/caselaws?id=369217 The Tribunal held that an entity-level approach is incorrect when dealing with transactions involving both Associated Enterprises (AE) and Non-AE, emphasizing that the Transactional Net Margin Method (TNMM) should only be applied at the transactional level. Additionally, the Tribunal ruled that segmental results should not be rejected solely for not being audited, stating that Tax Authorities must consider them for Transfer Pricing (TP) analysis. The case was remanded for fresh determination, directing the Transfer Pricing Officer (TPO) to reconsider the issues in line with the Tribunal's findings. The appeal of the assessee was treated as allowed for statistical purposes. en-us Mon, 22 Oct 2018 00:00:00 +0530 Mon, 22 Oct 2018 20:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369217 The Tribunal held that an entity-level approach is incorrect when dealing with transactions involving both Associated Enterprises (AE) and Non-AE, emphasizing that the Transactional Net Margin Method (TNMM) should only be applied at the transactional level. Additionally, the Tribunal ruled that segmental results should not be rejected solely for not being audited, stating that Tax Authorities must consider them for Transfer Pricing (TP) analysis. The case was remanded for fresh determination, directing the Transfer Pricing Officer (TPO) to reconsider the issues in line with the Tribunal's findings. The appeal of the assessee was treated as allowed for statistical purposes. Case-Laws Income Tax Mon, 22 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369217