2018 (3) TMI 1214

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.... Respondent.   P.C: This Appeal under Section 260A of the Income Tax Act, 1961 (the Act), challenges the order dated 30th January, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). The common impugned order dated 30th January, 2015 disposes of the appeal, relates to Assessment Years 2005-06, 2006-07 and 2007-08. This appeal is in respect of Assessment Year 2005-06. &nb....

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....is of its sales, is of parts. 4. The Respondent-Assessee sell its parts in the international market to its Associated Enterprises (AE). The Respondent-Assessee adopted the Transaction Net Margin (TNM) Method as most appropriate method to arrive at the Arms Length Price (ALP) of its transactions with AE. The Transfer Pricing Officer (TPO) while accepting the TNM method as the most appropriate me....

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....s derived from sale of parts alone. Thus, CIT(A) while allowing the appeal, deleted the addition of Rs. 62.72 lakhs. 6. Being aggrieved with the order dated 30th January, 2015 of the CIT(A), the Revenue filed an appeal to Tribunal. On examination of facts, the Tribunal further found that there was difference in the nature of customers in the domestic and export market. The impugned order on FAR....