https://www.taxtmi.com/caselaws?id=436591 Where TNMM had already been applied to the tested trading segment and its margins were not rejected, a separate transfer pricing adjustment for AMP expenditure was held impermissible absent proof of a distinct international transaction, and the AMP adjustment was deleted. In the business support services segment, comparables had to meet functional similarity: Majestic Research Services & Solutions Ltd. and Scarecrow Communications Ltd. were excluded as functionally dissimilar, while Pressman Advertising Ltd. required fresh examination by the lower authority, resulting in partial relief to the assessee. en-us Thu, 22 Dec 2022 00:00:00 +0530 Fri, 14 Apr 2023 14:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436591 Where TNMM had already been applied to the tested trading segment and its margins were not rejected, a separate transfer pricing adjustment for AMP expenditure was held impermissible absent proof of a distinct international transaction, and the AMP adjustment was deleted. In the business support services segment, comparables had to meet functional similarity: Majestic Research Services & Solutions Ltd. and Scarecrow Communications Ltd. were excluded as functionally dissimilar, while Pressman Advertising Ltd. required fresh examination by the lower authority, resulting in partial relief to the assessee. Case-Laws Income Tax Thu, 22 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436591