TMI Blog2019 (6) TMI 1529X X X X Extracts X X X X X X X X Extracts X X X X ..... he adjustment for only international transaction BUT Tribunal held that the TPO was not justified in making adjustment to the entire segment of manufacturing activity without restricting the same to the manufacturing transactionHELD THAT:- Tribunal in the process relied upon and referred to the decision of the Division Bench of this Court in case of CIT v. Tara Jewels Exports (P.) Ltd [ 2015 (12) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (i) Whether on the facts and circumstances of the case and in law, the ITAT was correct in setting aside the adjustment made by the TPO in respect of import of raw material to the file of the TPO, for pro-rata adjustment considering only the AE transactions, when this was not a ground raised either by Revenue or by the assessee and segmental accounts (in respect of AE and non-AE transactions were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing activity instead of making the adjustment for only international transaction. The Tribunal held that the TPO was not justified in making adjustment to the entire segment of manufacturing activity without restricting the same to the manufacturing transaction. The Tribunal in the process relied upon and referred to the decision of the Division Bench of this Court in case of CIT v. Tara Jewels Ex ..... X X X X Extracts X X X X X X X X Extracts X X X X
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