TPO couldn’t adopt TNMM to make TP adjustment without showing that segmental accounts were manipulat

IT/ILT: Where assessee, engaged in business of rendering inbound, outbound and domestic travel services to AEs, submitted accounts of inbounds and outbounds segments separately showing that international transactions were entered into at ALP, in absence of any evidence to show that those segmental accounts were manipulated, TPO was not justified in adopting TNMM and making addition to assessee's ALP on basis of weighted margin earned by external comparables