https://www.taxtmi.com/caselaws?id=794787 Where reliable segmental data for AE and non-AE transactions is available, internal TNMM must be preferred over external comparables unless cogent reasons justify rejection; the transfer pricing adjustment was therefore unsustainable and deleted. Losses linked to extraordinary COVID-19 disruptions, including shutdowns and under-absorption of fixed costs, did not by themselves indicate non-arm's length pricing. Disallowances of miscellaneous expenses, repairs and maintenance, rent, and bad debts were set aside because the assessment order did not identify specific defects or item-wise allowability issues; the matters were remanded for fresh verification with supporting evidence and hearing. en-us Mon, 12 Jan 2026 00:00:00 +0530 Sat, 11 Jul 2026 08:46:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794787 Where reliable segmental data for AE and non-AE transactions is available, internal TNMM must be preferred over external comparables unless cogent reasons justify rejection; the transfer pricing adjustment was therefore unsustainable and deleted. Losses linked to extraordinary COVID-19 disruptions, including shutdowns and under-absorption of fixed costs, did not by themselves indicate non-arm's length pricing. Disallowances of miscellaneous expenses, repairs and maintenance, rent, and bad debts were set aside because the assessment order did not identify specific defects or item-wise allowability issues; the matters were remanded for fresh verification with supporting evidence and hearing. Case-Laws Income Tax Mon, 12 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794787