https://www.taxtmi.com/caselaws?id=799443 Internal comparables derived from audited segmental accounts should be preferred to external comparables under the Transactional Net Margin Method when they are available and suitable for determining the arm's length price. Reliability depends on sales being allocated using actual invoice-level data, common expenses being apportioned on a rational basis, and the allocation methodology being supported by chartered accountant certification. Where these conditions are satisfied and the supporting factual findings are not perverse, internal comparables support deletion of an upward transfer-pricing adjustment. en-us Tue, 15 Sep 2026 00:00:00 +0530 Tue, 22 Sep 2026 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799443 Internal comparables derived from audited segmental accounts should be preferred to external comparables under the Transactional Net Margin Method when they are available and suitable for determining the arm's length price. Reliability depends on sales being allocated using actual invoice-level data, common expenses being apportioned on a rational basis, and the allocation methodology being supported by chartered accountant certification. Where these conditions are satisfied and the supporting factual findings are not perverse, internal comparables support deletion of an upward transfer-pricing adjustment. Case-Laws Income Tax Tue, 15 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799443