“Egg-or-Chicken” Analogy Applied – ITAT Says Trading & Service Functions Can’t Be Split

Juniper Networks Solution India Pvt. Ltd. Vs Assessment Unit (ITAT Delhi)

Delhi ITAT held that Juniper’s trading and after-sales service activities were inseparably linked, forming one integrated business. Rejecting the TPO’s revenue-based segmentation as artificial, the Tribunal applied the “egg-or-chicken” analogy to emphasize their interdependence, upheld entity-level TNMM, and deleted the ₹16.86-crore transfer pricing adjustment.

Delhi Tribunal allowed Juniper’s appeal by holding that its trading & service operations formed one integrated

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