Assessee Can Use Segmental Details for Transfer Pricing Adjustments in Design Engineering Services Case.

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....TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental details during TP or DRP proceedings in order to benchmark the margins of its international transactions on the basis of segmental profitability of AE segment - segmental details are to be adopted and margins of segment of AE transactions are compared with margins of comparables selected....