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2022 (1) TMI 1304 - ITAT DELHITP Adjustment - segment reporting in the financial of the taxpayer that established its action of distributing of revenue between foreign AE and non-AE as genuine allocation - HELD THAT:- The assessee 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 view of the above submission, relying on the judgment in the case of Birla Soft India Ltd. [2013 (11) TMI 417 - ITAT DELHI] as directed the TPO/AO to determine the ALP of the international transactions with the AE by making internal comparison of the net margins earned by the appellant from international transaction with AE and margin earned by the AE from international transactions with unrelated parties. AO/TPO was further directed to 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. Appeal of the revenue is dismissed.
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