Segmental Profitability Essential in Transfer Pricing; Audited Accounts Can Be Scrutinized Beyond Chartered Accountant Certification.

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....TP Adjustment - segmental profitability consideration for benchmarking analysis - The segmental accounting prepared cannot be rejected without pointing out defects in the allocation done by the assessee. Moreover, it is also noted that accounts are duly audited. There is also no rule that if segmental accounts are certified by CA. the AO should stop application of mind and follow it as a gospel truth. - AT....