https://www.taxtmi.com/caselaws?id=389573 The appeal was dismissed, affirming the transfer pricing adjustment in the production segment. The court upheld the authorities' decision to reject the aggregation approach and require separate benchmarking of manufacturing and trading segments. The High Court emphasized the lack of close link between the segments, supporting separate benchmarking for transactions not part of a composite transaction. The decision highlighted the need for technical know-how for aggregation, which was deemed unnecessary in this case. The transfer pricing addition in the production segment was justified due to the lack of closely linked transactions for aggregation. en-us Mon, 09 Dec 2019 00:00:00 +0530 Wed, 11 Dec 2019 14:42:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389573 The appeal was dismissed, affirming the transfer pricing adjustment in the production segment. The court upheld the authorities' decision to reject the aggregation approach and require separate benchmarking of manufacturing and trading segments. The High Court emphasized the lack of close link between the segments, supporting separate benchmarking for transactions not part of a composite transaction. The decision highlighted the need for technical know-how for aggregation, which was deemed unnecessary in this case. The transfer pricing addition in the production segment was justified due to the lack of closely linked transactions for aggregation. Case-Laws Income Tax Mon, 09 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389573