https://www.taxtmi.com/caselaws?id=758852 ITAT Delhi allowed appellant's application to admit additional evidence comprising segmental financial statements for benchmarking specified domestic transactions with associated enterprise LPTPL. The tribunal found that segmental accounts, now certified by independent accountant, were necessary to properly evaluate internal TNMM method for determining arm's length pricing. DRP had earlier rejected these statements as unaudited and unreliable. ITAT held that without considering segmental analysis comparing transactions with LPTPL versus third party ARBL, rejection of internal TNMM method would violate natural justice principles. Additional evidence was admitted for statistical purposes as it had direct bearing on determining appropriate transfer pricing method. en-us Fri, 31 May 2024 00:00:00 +0530 Thu, 19 Sep 2024 18:18:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758852 ITAT Delhi allowed appellant's application to admit additional evidence comprising segmental financial statements for benchmarking specified domestic transactions with associated enterprise LPTPL. The tribunal found that segmental accounts, now certified by independent accountant, were necessary to properly evaluate internal TNMM method for determining arm's length pricing. DRP had earlier rejected these statements as unaudited and unreliable. ITAT held that without considering segmental analysis comparing transactions with LPTPL versus third party ARBL, rejection of internal TNMM method would violate natural justice principles. Additional evidence was admitted for statistical purposes as it had direct bearing on determining appropriate transfer pricing method. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758852