https://www.taxtmi.com/highlights?id=95879 Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT en-us Fri, 09 Jan 2026 12:07:19 +0530 Fri, 09 Jan 2026 12:07:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95879 Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT Highlights Income Tax Fri, 09 Jan 2026 12:07:19 +0530 https://www.taxtmi.com/highlights?id=95879