https://www.taxtmi.com/caselaws?id=465159 ITAT held that, for AY 2012-13, the TP benchmarking of the assessee's international transactions must separately and independently evaluate its trading and manufacturing segments. The order of the CIT(A) was set aside and the matter remanded to the AO/TPO for fresh benchmarking after due opportunity of hearing. On the provision for slow-moving/obsolete inventory, ITAT directed the AO to verify whether such provisions are written back upon sale; if so, the corresponding deduction is allowable and must be factored into ALP determination. ITAT further directed that any TP adjustment be strictly confined to the assessee's international transactions with its AEs. en-us Fri, 05 Mar 2021 00:00:00 +0530 Mon, 08 Dec 2025 12:30:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465159 ITAT held that, for AY 2012-13, the TP benchmarking of the assessee's international transactions must separately and independently evaluate its trading and manufacturing segments. The order of the CIT(A) was set aside and the matter remanded to the AO/TPO for fresh benchmarking after due opportunity of hearing. On the provision for slow-moving/obsolete inventory, ITAT directed the AO to verify whether such provisions are written back upon sale; if so, the corresponding deduction is allowable and must be factored into ALP determination. ITAT further directed that any TP adjustment be strictly confined to the assessee's international transactions with its AEs. Case-Laws Income Tax Fri, 05 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465159