https://www.taxtmi.com/caselaws?id=307542 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s acceptance of segment reporting and rejecting the ALP adjustment made by the TPO/AO. The Tribunal emphasized the importance of segmental results in transfer pricing analysis and highlighted the necessity of comparing net profit margins from international transactions with comparable uncontrolled transactions, rather than applying entity-level assessments. en-us Wed, 24 Apr 2019 00:00:00 +0530 Thu, 20 Apr 2023 21:14:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307542 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s acceptance of segment reporting and rejecting the ALP adjustment made by the TPO/AO. The Tribunal emphasized the importance of segmental results in transfer pricing analysis and highlighted the necessity of comparing net profit margins from international transactions with comparable uncontrolled transactions, rather than applying entity-level assessments. Case-Laws Income Tax Wed, 24 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307542