https://www.taxtmi.com/caselaws?id=792852 Where segmental results for associated enterprise transactions are available and reliably certified, transfer pricing should be benchmarked on those transactions rather than at the entity level; rejection of segmental analysis merely because it is unaudited is unsustainable. Comparables must also satisfy functional, asset and risk comparability, and entities with materially different business profiles, such as retail, manufacturing, contract manufacturing, leather garments or merger-acquisition situations, or with inadequate export revenue, should be excluded. The comparables exercise was remitted for fresh examination, and the assessee was to be considered for the statutory +/- 5% tolerance under section 92C(2). en-us Tue, 02 Jun 2026 00:00:00 +0530 Thu, 04 Jun 2026 08:37:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792852 Where segmental results for associated enterprise transactions are available and reliably certified, transfer pricing should be benchmarked on those transactions rather than at the entity level; rejection of segmental analysis merely because it is unaudited is unsustainable. Comparables must also satisfy functional, asset and risk comparability, and entities with materially different business profiles, such as retail, manufacturing, contract manufacturing, leather garments or merger-acquisition situations, or with inadequate export revenue, should be excluded. The comparables exercise was remitted for fresh examination, and the assessee was to be considered for the statutory +/- 5% tolerance under section 92C(2). Case-Laws Income Tax Tue, 02 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792852