https://www.taxtmi.com/caselaws?id=391811 The Tribunal directed the Transfer Pricing Officer to reevaluate using internal comparables based on the taxpayer's provided segmental accounts, emphasizing the importance of internal data for determining the Arm's Length Price (ALP) in international transactions. The Tribunal also instructed the TPO to reconsider the benchmarking methodology based on internal data, highlighting the necessity of proper documentation and specific criteria for selecting comparable companies. The decision implied a potential consideration of the requested variation in ALP determination and indicated a chance for further submissions based on the provided segmental accounts. en-us Wed, 29 Jan 2020 00:00:00 +0530 Fri, 07 Feb 2020 11:15:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391811 The Tribunal directed the Transfer Pricing Officer to reevaluate using internal comparables based on the taxpayer's provided segmental accounts, emphasizing the importance of internal data for determining the Arm's Length Price (ALP) in international transactions. The Tribunal also instructed the TPO to reconsider the benchmarking methodology based on internal data, highlighting the necessity of proper documentation and specific criteria for selecting comparable companies. The decision implied a potential consideration of the requested variation in ALP determination and indicated a chance for further submissions based on the provided segmental accounts. Case-Laws Income Tax Wed, 29 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391811