TPO Must Assess Internal Comparables First in Transfer Pricing; External TNMM Used Only If Necessary.

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....Transfer pricing Adjustments - ALP - Once internal comparable was available, along with the segmental details, TPO was required to examine the same and carry out the comparability analysis. It is only when internal TNMM fails, the TPO can go into search for external TNMM because external comparable require lot of functionality test and adjustments - AT....