TNMM Doesn’t Mandate Audited Segmental Accounts for Internal Comparables

Lummus Technology Heat Transfer BV Vs DCIT (ITAT Delhi) ITAT had held that Rule 10B(1)(e) of the Income Tax Rules, dealing with TNMM, does not mandate that net profit computations for internal comparables be based on audited segmental accounts. The Tribunal had observed that computation on the same parameters for controlled and uncontrolled transactions is sufficient, provided necessary comparability adjustments are made. Overview: The case involves Lummus Technology Heat Transfer BV, a Dutch company with a branch office in India that specializes in designing, engineering, and construction...