https://www.taxtmi.com/caselaws?id=465567 The dominant issue was whether the TPO could reject the assessee's segmental accounts and benchmark international transactions on an entity-wide basis. The Tribunal held that domestic-segment losses, explained by severe competition, premium pricing in international segments, higher quality-cost standards, and the industry's long gestation period, did not justify discarding segmental results; consistent acceptance in an earlier year reinforced this. Segmental accounts were directed to be accepted and the assessee's benchmarking not to be rejected. The Tribunal further held that, even if entity-wide margins were applied, any TP adjustment must be restricted to the value of international transactions, and a pending SLP could not dilute binding jurisdictional precedent. Working-capital adjustment was directed to be applied consistently, multiple non-comparable companies were excluded, and the assessee's AE margins were held at ALP, resulting in deletion of TP adjustment. en-us Fri, 18 May 2018 00:00:00 +0530 Mon, 29 Dec 2025 16:27:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465567 The dominant issue was whether the TPO could reject the assessee's segmental accounts and benchmark international transactions on an entity-wide basis. The Tribunal held that domestic-segment losses, explained by severe competition, premium pricing in international segments, higher quality-cost standards, and the industry's long gestation period, did not justify discarding segmental results; consistent acceptance in an earlier year reinforced this. Segmental accounts were directed to be accepted and the assessee's benchmarking not to be rejected. The Tribunal further held that, even if entity-wide margins were applied, any TP adjustment must be restricted to the value of international transactions, and a pending SLP could not dilute binding jurisdictional precedent. Working-capital adjustment was directed to be applied consistently, multiple non-comparable companies were excluded, and the assessee's AE margins were held at ALP, resulting in deletion of TP adjustment. Case-Laws Income Tax Fri, 18 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465567