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TMI Blog2016 (8) TMI 1510X X X X Extracts X X X X X X X X Extracts X X X X ..... at entity level - whether if the overall margins are less than the arms length margin, the short fall must be on account of the Associate Enterprise transactions and not on pro-rata basis? - HELD THAT:- The impugned order of the Tribunal decided the issue framed herein in favour of the respondent assessee by following its decision in CIT v. Thyssen Krupp Industries India (P.) Ltd. [2015 (12) TMI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lowing substantial question of law:- (i) Whether on the facts and circumstances of the case and in law, the Tribunal erred in law in directing the Assessing Officer to restrict the adjustments only in relation to the transactions with the Associate Enterprise and not on the entire revenue of manufacturing segment without appreciating the fact that the assessee has selected Transactional Net Ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssen Krupp Industries India (P.) Ltd. (supra)) and Income Tax Appeal No. 1814 of 2013 (Tara Jewels Exports (P.) Ltd. (supra)). By order dated 2nd December, 2015 in Income Tax Appeal No. 2201 of 2013 and order dated 5th October, 2015 in Income Tax Appeal No. 1814 of 2013, the Revenue's appeals were dismissed. As the impugned order of the Tribunal follows its orders in Thyssen Krupp Industries ( ..... X X X X Extracts X X X X X X X X Extracts X X X X
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