https://www.taxtmi.com/caselaws?id=472004 Internal TNMM should be preferred over external comparables where associated-enterprise and independent-party transactions involve comparable products, functions, assets and risks. Segmental financials need not be separately audited if reasonably prepared, reconciled with audited books and supported by a consistent allocation methodology. Invoice-level sales allocation, reasonable allocation keys for common expenses, and direct allocation of expenses exclusively relating to non-associated-enterprise sales support reliability. In the absence of identified defects, arbitrary allocations or profit shifting, a higher associated-enterprise segment margin supports arm's-length pricing and deletion of the transfer-pricing adjustment. en-us Wed, 31 Dec 2025 00:00:00 +0530 Fri, 25 Sep 2026 20:15:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472004 Internal TNMM should be preferred over external comparables where associated-enterprise and independent-party transactions involve comparable products, functions, assets and risks. Segmental financials need not be separately audited if reasonably prepared, reconciled with audited books and supported by a consistent allocation methodology. Invoice-level sales allocation, reasonable allocation keys for common expenses, and direct allocation of expenses exclusively relating to non-associated-enterprise sales support reliability. In the absence of identified defects, arbitrary allocations or profit shifting, a higher associated-enterprise segment margin supports arm's-length pricing and deletion of the transfer-pricing adjustment. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472004