https://www.taxtmi.com/caselaws?id=768116 ITAT DELHI upheld TPO's segmentation of assessee's business into Manufacturing and Trading for transfer pricing benchmarking, following coordinate bench precedent. TNMM application instead of Cost-Plus Method was confirmed, with assessee treated as tested party. For comparable selection, TPO directed to use undisputed comparables from AYs 2012-13 to 2014-15 with respective year financial data for both segments separately. Capacity utilization disallowance matter restored to TPO for verification. Custom duty adjustment issue remitted to TPO for fresh adjudication considering functional differences and business model factors. Foreign exchange gains/losses confirmed as operating revenue items. Working capital adjustment decided favoring assessee following previous precedent. en-us Thu, 27 Mar 2025 00:00:00 +0530 Tue, 01 Apr 2025 11:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768116 ITAT DELHI upheld TPO's segmentation of assessee's business into Manufacturing and Trading for transfer pricing benchmarking, following coordinate bench precedent. TNMM application instead of Cost-Plus Method was confirmed, with assessee treated as tested party. For comparable selection, TPO directed to use undisputed comparables from AYs 2012-13 to 2014-15 with respective year financial data for both segments separately. Capacity utilization disallowance matter restored to TPO for verification. Custom duty adjustment issue remitted to TPO for fresh adjudication considering functional differences and business model factors. Foreign exchange gains/losses confirmed as operating revenue items. Working capital adjustment decided favoring assessee following previous precedent. Case-Laws Income Tax Thu, 27 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768116