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TMI Blog2022 (1) TMI 1304X X X X Extracts X X X X X X X X Extracts X X X X ..... e has enclosed the export segment results, indicating that the assessee has made operating prof it in its export sales. A duly certified segment accounts by a Chartered Accountant is enclosed as an annexure to this submission, which proves that the assessee has earned margin of 0.74% on overall export sales to AE segment as against the margin of 0.39% on export sales to non-AE segment. CIT(A), in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Member: The present appeal has been filed by the revenue against the order of ld. CIT(A)-44, New Delhi dated 28.02.2018. 2. Following grounds have been raised by the revenue: "1. Whether the order of ld. CIT(A) is perverse in accepting the internal TNMM of the assessee ignoring the fact that the assessee company has been changing its stand before the authorities and even offered adjustment u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ay inspite of a lag of three months. At this juncture we feel it is no more required. Hence, it is decided to dispose the appeal on the merits of the case. 4. In the case, the AO made addition on account of Transfer Pricing adjustment of Rs.1,67,85,136/- which culminated into contraption of returned loss of Rs.7,80,30,578/- to Rs.6,12,26,929/- The assessee has enclosed the export segment results, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o calculate the costs of the segments on the basis of the certificate of the CA which has not been objected by the TPO on the remand report. 5. Since, we find no error of law or facts on the directions of the ld. CIT(A) given to the TPO/AO, we hold that the appeal fi led by the revenue is infructuous and being dismissed. 6. In the result, the appeal of the revenue is dismissed. Order Pronounced ..... X X X X Extracts X X X X X X X X Extracts X X X X
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