https://www.taxtmi.com/caselaws?id=794521 Segmental profitability supported by contemporaneous audit material and cost allocation cannot be rejected in transfer pricing proceedings merely because the revenue prefers an entity-level benchmark. Where the assessee shows distinct AE and non-AE functions and risk profiles, and the same segmental method has been accepted in earlier and later years without any material change in facts, the adjustment based on rejection of segmental results is not sustainable unless specific defects are identified. On the section 80G deduction and advance tax credit issues, the matter remained for rectification consideration before the AO, who was directed to pass orders in accordance with law. en-us Wed, 24 Jun 2026 00:00:00 +0530 Tue, 07 Jul 2026 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794521 Segmental profitability supported by contemporaneous audit material and cost allocation cannot be rejected in transfer pricing proceedings merely because the revenue prefers an entity-level benchmark. Where the assessee shows distinct AE and non-AE functions and risk profiles, and the same segmental method has been accepted in earlier and later years without any material change in facts, the adjustment based on rejection of segmental results is not sustainable unless specific defects are identified. On the section 80G deduction and advance tax credit issues, the matter remained for rectification consideration before the AO, who was directed to pass orders in accordance with law. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794521