Assessee Failed to Allocate Employee Costs and Expenses Between Trading and Manufacturing Segments Despite TPO's Opportunity.

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....TP Adjustment - allocate various costs between the ‘Trading’ and ‘Manufacturing’ segments - Despite an opportunity granted by the TPO, the assessee still did not come clean by not properly allocating Employee cost, Depreciation and Other expenses as discussed supra. This demonstrates that the assessee failed to properly apportion the expenses between the manufacturing and trading segments, as has been correctly adjudicated by the ld. CIT(A). - AT....