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TMI Blog2017 (6) TMI 1240X X X X Extracts X X X X X X X X Extracts X X X X ..... or Counsel a/w Mr. Atul K. Jasani ORDER PER COURT : The Revenue has filed the present appeal against the order of the Tribunal. The present matter pertains to the Assessment Year 20082009. 2 The Revenue has filed the appeal on following grounds, stating to be the substantial questions of law: "6.1 Whether on the facts and in the circumstances of the case, the Hon'ble Tribunal was correct ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only. According to the learned counsel, the entire turnover of the Company was required to be considered for determination of A.L.P. According to the learned counsel, the D.R.P. was right in observing that there was no segmental audit of the transactions of AE nonAE and therefore there was no method whereby the Assessing Officer could come to the conclusion of fair determination of ALP in restrain ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve parties, we have considered the submissions and the judgment of the Tribunal. The Tribunal in para 7 of it's order has observed as under. "7 We have heard both the parties and their contention have carefully been considered. So far it relates to grievance of the assessee that the TP adjustment can only be applied to international transactions of the assessee with the AE and it cannot be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It would be clear that the details of the international transaction are specifically made available and therefore the apprehension of the department as such is misplaced. 7 Moreover this Court in Income Tax Appeal NO. 362 of 2014 has dealt with the aspect of absence of segmental accounts. While delivering the order in the aforesaid Appeal No. 362 of 2014, the Court has also considered the order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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