https://www.taxtmi.com/caselaws?id=753043 The ITAT Hyderabad ruled in favor of the assessee on transfer pricing adjustments, directing that benchmarking should be restricted to transactions with associated enterprises (AEs) only, not entity-level comparisons. The tribunal restored multiple issues to the Assessing Officer/TPO including: consideration of segmental information for AE transactions only when determining arm's length price, evaluation of appropriate most appropriate method (MAM) selection for manufacturing versus trading segments, verification of whether resale price method should apply to trading activities without value addition, and proper classification of business segments based on transaction volumes. The appeal was allowed for statistical purposes with directions for fresh consideration of segmental margins and transaction-specific analysis. en-us Tue, 21 May 2024 00:00:00 +0530 Thu, 23 May 2024 08:37:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753043 The ITAT Hyderabad ruled in favor of the assessee on transfer pricing adjustments, directing that benchmarking should be restricted to transactions with associated enterprises (AEs) only, not entity-level comparisons. The tribunal restored multiple issues to the Assessing Officer/TPO including: consideration of segmental information for AE transactions only when determining arm's length price, evaluation of appropriate most appropriate method (MAM) selection for manufacturing versus trading segments, verification of whether resale price method should apply to trading activities without value addition, and proper classification of business segments based on transaction volumes. The appeal was allowed for statistical purposes with directions for fresh consideration of segmental margins and transaction-specific analysis. Case-Laws Income Tax Tue, 21 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753043