https://www.taxtmi.com/caselaws?id=468241 Reliable segmental data justified benchmarking the manufacturing segment under Internal TNMM rather than External TNMM, because internal comparables provided a more direct arm's length test and the objections on turnover and functional differences were not persuasive. Miscellaneous expenses were to be treated consistently as operating items for both the assessee and comparables, since they formed part of normal business operations and differential treatment would distort margin computation. Notional interest on outstanding receivables was unsustainable where the assessee's payables to associated enterprises exceeded its receivables, so the receivable adjustment was deleted. The Tribunal therefore deleted the transfer pricing additions. en-us Thu, 14 Aug 2025 00:00:00 +0530 Thu, 23 Apr 2026 20:01:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468241 Reliable segmental data justified benchmarking the manufacturing segment under Internal TNMM rather than External TNMM, because internal comparables provided a more direct arm's length test and the objections on turnover and functional differences were not persuasive. Miscellaneous expenses were to be treated consistently as operating items for both the assessee and comparables, since they formed part of normal business operations and differential treatment would distort margin computation. Notional interest on outstanding receivables was unsustainable where the assessee's payables to associated enterprises exceeded its receivables, so the receivable adjustment was deleted. The Tribunal therefore deleted the transfer pricing additions. Case-Laws Income Tax Thu, 14 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468241