2015 (7) TMI 434

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....nt made to the income on account of international transactions with Associated Enterprises. He submitted that the Hon'ble Tribunal in para No.28.3 of its order agreed with the contention of the appellant that the manufacturing segment of the appellant cannot be further bifurcated into DTA and EOU, it has not given clear directions to the CIT(A) to apply TNM Method by considering both the segments together. He submitted that this Tribunal may be pleased to issue specific directions to this effect to avoid any repetitive limitation on this issue. 3. On the contrary, ld.Sr.DR Shri M.K. Singh vehemently opposed the miscellaneous application of the assessee and submitted that the ld.counsel for the assessee has not pointed out any mistake appar....

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....tion in the nature of capital Goods, part of the Balance Sheet of Rs. 5,19,25,936, aggregating to Rs. 14,81,68,414.            e. From the above, reduction of the Royalty (of DTA and EOU Segment both) of Rs. 6,38,26,098. It may be noted that Royalty of EOU of Rs. 1,51,01,703 was not included in the above aggregate. Despite this fact, it was reduced from the aggregate. The ld. counsel for the assessee submitted that for the purpose of benchmarking the international transactions the assessee had bifurcated its activities into manufacturing segment and distribution segment. However, the Transfer Pricing Officer (TPO) has further bifurcated the activities of the assessee into domestic unit (DT....