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TMI Blog2017 (8) TMI 1475X X X X Extracts X X X X X X X X Extracts X X X X ..... ion.” However, with these corrections there would be no change in the final result of the appeal and the cross objections. - MA No. 41/PUN/2016 (Arising out of CO No. 53/PUN/2014) - - - Dated:- 16-8-2017 - Shri Anil Chaturvedi And Shri Vikas Awasthy, JJ. Assessee by : S/Shri Arvind Sondhe Ketan Ved Revenue by : Shri Achal Sharma ORDER Vikas Awasthy, This Miscellaneous Application has been filed by the assessee seeking rectification in the order of Tribunal dated 29-01-2016 vide which ITA No. 594/PN/2013 of the Revenue and Cross Objection No. 53/PN/2014 by the assessee were adjudicated. 2. Shri Arvind Sondhe appearing on behalf of the assessee submitted that the Tribunal in para 38 at page 20 of the or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rocurement support services. It was argued that the procurement support services ought to be aggregated with manufacturing function under Transactional Net Margin Method (TNMM) since, the services are closely linked to the main activity of manufacturing. The AR of the assessee had also relied on the decisions submitted as part of legal compilation. However, the Tribunal while disposing of cross objections of the assessee had mentioned that ground No. 3 is not pressed. The ld. AR pointed that admittedly the submissions were made in respect of ground No. 3.1 only and no submissions were made in respect of ground No. 3.2 and 3.3. The ld. AR prayed for rectifying the error in para 38 of the order of Tribunal dated 29-01-2016. 3. Shri Achal S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... above corrections carried out in para 38 at page 20 of the order, corrected para 38 be read as under : 38. Grounds No. 2 and 3.1 of the CO require no adjudication being academic in nature. Grounds No. 3.2, 3.3 and 5 of the CO were not pressed by Ld. Authorised Representative. Grounds of appeal No. 6 and 7 being general are dismissed. Thus, we are left with only Ground of appeal No. 4 which relates the order of the CIT(A) in confirming the adjustment of ₹ 78,72,507/- to the value of international transactions in respect of export of IC engines by the LHP Division. 7. However, with these corrections there would be no change in the final result of the appeal and the cross objections. 8. In view of the corrections made in orde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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