https://www.taxtmi.com/caselaws?id=787768 Where reliable segmental accounts supported by functional, asset and risk analysis are available, transfer pricing benchmarking must be undertaken segment-wise rather than by aggregating distinct businesses at entity level. Unaudited segment accounts cannot be rejected merely on that basis; a specific defect must be shown before they are disregarded. The document states that the assessee's AMC services and agency and marketing support services were treated as separate segments, and that comparables and margins had to be examined accordingly. The matter was therefore restored for limited verification of the segmental accounts, comparables, and whether the tested-party margin fell within the permissible tolerance range. en-us Wed, 17 Dec 2025 00:00:00 +0530 Thu, 12 Mar 2026 08:33:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787768 Where reliable segmental accounts supported by functional, asset and risk analysis are available, transfer pricing benchmarking must be undertaken segment-wise rather than by aggregating distinct businesses at entity level. Unaudited segment accounts cannot be rejected merely on that basis; a specific defect must be shown before they are disregarded. The document states that the assessee's AMC services and agency and marketing support services were treated as separate segments, and that comparables and margins had to be examined accordingly. The matter was therefore restored for limited verification of the segmental accounts, comparables, and whether the tested-party margin fell within the permissible tolerance range. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787768