https://www.taxtmi.com/caselaws?id=784655 On TP adjustment under s.92, the Tribunal held that combining the indenting/marketing support segment with the trading of spare parts (AMC) segment was improper where the assessee had presented distinct segments; accordingly, the AO/TPO was directed to accept the two-segment characterization, redo benchmarking segment-wise after considering the assessee's comparables and submissions, and re-test the ALP within the proviso to s.92C(2) tolerance range, with the ALP issue remanded. On characterization of non-compete fee, in light of the latest SC ruling settling the law, the AO was directed to treat the non-compete fee as revenue in nature and to rework consequential depreciation treatment already claimed, applying the relevant guidance, resulting in remand for recomputation. en-us Wed, 07 Jan 2026 00:00:00 +0530 Fri, 09 Jan 2026 08:29:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784655 On TP adjustment under s.92, the Tribunal held that combining the indenting/marketing support segment with the trading of spare parts (AMC) segment was improper where the assessee had presented distinct segments; accordingly, the AO/TPO was directed to accept the two-segment characterization, redo benchmarking segment-wise after considering the assessee's comparables and submissions, and re-test the ALP within the proviso to s.92C(2) tolerance range, with the ALP issue remanded. On characterization of non-compete fee, in light of the latest SC ruling settling the law, the AO was directed to treat the non-compete fee as revenue in nature and to rework consequential depreciation treatment already claimed, applying the relevant guidance, resulting in remand for recomputation. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784655