TNMM Entity level to be accepted as opposed to artificial vivisection

This ruling reinforces a core transfer pricing principle, where business operations are functionally integrated, segmentation is impermissible unless clearly warranted. 

The Tribunal relied on consistency with its own prior year ruling and emphasized that post-sale services, warranty support, and distribution functions form a unified value chain. By rejecting mechanical allocation keys and segmentation, the decision restores primacy to economic substance over computational convenience.