https://www.taxtmi.com/caselaws?id=434485 Transfer pricing under Chapter X is to be benchmarked at the level of the specific international transaction, not at entity level, and the arm's length price must reflect the relevant manufacturing segment only. The recomputation should use audited segmental results and operating items, while excluding non-operating heads such as foreign exchange gains or losses, provisions for bad and doubtful debts, and provisions written back. Income from management support services, being part of a different segment, should not be merged into the manufacturing benchmark. The fresh computation was left to the Transfer Pricing Officer on this segment-specific and transaction-specific basis. en-us Thu, 13 Oct 2022 00:00:00 +0530 Fri, 24 Feb 2023 18:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434485 Transfer pricing under Chapter X is to be benchmarked at the level of the specific international transaction, not at entity level, and the arm's length price must reflect the relevant manufacturing segment only. The recomputation should use audited segmental results and operating items, while excluding non-operating heads such as foreign exchange gains or losses, provisions for bad and doubtful debts, and provisions written back. Income from management support services, being part of a different segment, should not be merged into the manufacturing benchmark. The fresh computation was left to the Transfer Pricing Officer on this segment-specific and transaction-specific basis. Case-Laws Income Tax Thu, 13 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434485