https://www.taxtmi.com/caselaws?id=775838 The ITAT Chennai held that the TPO cannot reject the certified segmental comparison of AE and Non-AE entities when it had accepted the same basis of segmentation in the prior year without adjustment. Relying on precedent, the tribunal ruled that a consistent factual position established in earlier assessments should not be altered in subsequent years. The Internal TNMM was affirmed as the most appropriate method, especially when audited segmental data is available, and was preferred over external TNMM. The appeal was allowed, directing acceptance of the Internal TNMM based on audited segmentation certified by the external CA. en-us Wed, 04 Jun 2025 00:00:00 +0530 Fri, 01 Aug 2025 08:15:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775838 The ITAT Chennai held that the TPO cannot reject the certified segmental comparison of AE and Non-AE entities when it had accepted the same basis of segmentation in the prior year without adjustment. Relying on precedent, the tribunal ruled that a consistent factual position established in earlier assessments should not be altered in subsequent years. The Internal TNMM was affirmed as the most appropriate method, especially when audited segmental data is available, and was preferred over external TNMM. The appeal was allowed, directing acceptance of the Internal TNMM based on audited segmentation certified by the external CA. Case-Laws Income Tax Wed, 04 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775838