2018 (10) TMI 1824

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e very outset of the hearing of the application took us through the facts of the case, to the extent relevant for disposal of the present miscellaneous application. The ld. A.R submitted, that the assessee had carried the matter in appeal before the Tribunal against the final assessment order passed by the A.O in pursuance to the directions of the Dispute Resolution Panel, Mumbai (for short "DRP‟), for the year under consideration viz. A.Y 2012-13. It was submitted by the ld. A.R, that the said appeal was disposed off by the Tribunal, vide a consolidate order dated 21.08.2018. The ld. A.R taking us through the mistake apparent from record, which as per him had crept in the aforesaid order, submitted that the assessee had by way of a "....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....cturing segment (supply of raw material, packing materials and semi-finished goods) as the AE.s performed least complex functions, that the ground was applicable only to AY2008-09 as the appellant had manufacturing segment along with distribution segment, that from the AY.2009-10 onwards, the assessee was is engaged in only one segment being distribution segment ,that for the AY. 2009-10 to 2012-13, the distribution function of the assessee was to be considered as least complex as compared to manufacturing functions performed by the AE's." 3. In the backdrop of the aforesaid contention, it was submitted by the ld. A.R, that despite the fact that a specific "Ground of appeal No. 5" was raised by the assessee and contentions as regards the....