https://www.taxtmi.com/caselaws?id=798025 Transfer-pricing determination must separately examine the taxpayer's segmental break-up of income and expenses when determining the arm's length price. Disregarding a material segmental analysis, without substantively addressing objections to that treatment, requires reconsideration after providing an opportunity of hearing. The absence of a transfer-pricing adjustment in the subsequent assessment year formed part of the factual context supporting fresh examination. The determination therefore requires a fresh segment-wise analysis in accordance with law. en-us Tue, 25 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798025 Transfer-pricing determination must separately examine the taxpayer's segmental break-up of income and expenses when determining the arm's length price. Disregarding a material segmental analysis, without substantively addressing objections to that treatment, requires reconsideration after providing an opportunity of hearing. The absence of a transfer-pricing adjustment in the subsequent assessment year formed part of the factual context supporting fresh examination. The determination therefore requires a fresh segment-wise analysis in accordance with law. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798025