https://www.taxtmi.com/caselaws?id=792144 The assessee's aggregation of manufacturing and trading transactions for transfer pricing and its use of TNMM were sustained because the DRP found, on the facts, that the business model required combined evaluation of the segments and that TNMM had been consistently applied. The Tribunal did not disturb those concurrent factual findings, and the legal position was treated as covered by binding precedent that once the most appropriate method is accepted, the revenue cannot selectively apply a different method to one element of the same transfer pricing exercise. No substantial question of law was found to arise for interference. en-us Thu, 12 Mar 2026 00:00:00 +0530 Sat, 23 May 2026 08:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792144 The assessee's aggregation of manufacturing and trading transactions for transfer pricing and its use of TNMM were sustained because the DRP found, on the facts, that the business model required combined evaluation of the segments and that TNMM had been consistently applied. The Tribunal did not disturb those concurrent factual findings, and the legal position was treated as covered by binding precedent that once the most appropriate method is accepted, the revenue cannot selectively apply a different method to one element of the same transfer pricing exercise. No substantial question of law was found to arise for interference. Case-Laws Income Tax Thu, 12 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792144