https://www.taxtmi.com/caselaws?id=461979 Transfer pricing adjustment was deleted where the Tribunal accepted the assessee's internal TNMM based on segmental AE and non-AE results, and held that it could not be rejected merely because the segmental accounts were unaudited or because the TPO preferred a different cost-allocation method. The Tribunal also declined to sustain the external TNMM benchmarking and idle-capacity related adjustment, noting that the issue was already covered by the jurisdictional High Court in the assessee's own case. On the facts, the arm's length price adjustment was found unwarranted and the assessee succeeded on this issue. en-us Wed, 07 May 2025 00:00:00 +0530 Sat, 21 Mar 2026 11:47:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461979 Transfer pricing adjustment was deleted where the Tribunal accepted the assessee's internal TNMM based on segmental AE and non-AE results, and held that it could not be rejected merely because the segmental accounts were unaudited or because the TPO preferred a different cost-allocation method. The Tribunal also declined to sustain the external TNMM benchmarking and idle-capacity related adjustment, noting that the issue was already covered by the jurisdictional High Court in the assessee's own case. On the facts, the arm's length price adjustment was found unwarranted and the assessee succeeded on this issue. Case-Laws Income Tax Wed, 07 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461979