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Toyota Industries Engine India Vs. National e-Assessment Centre, Private Ltd., Delhi. / Plot No.9, Phase 2, Jigani Industrial Area, Jigani, The Assistant Commissioner Bangalore – 561 105. of Income-tax, PAN: AAACK 7425Q Circle 7(1)(1), Bangalore. APPELLANT RESPONDENT C O R R I G E N D U M Per Padmavathy S., Accountant Member This appeal was disposed of by this Tribunal vide order dated 13.05.2022.
Certain inadvertent errors have crept in paras 4 & 5 of the order of the Tribunal wherein the words ‘operating profit on sales’ are mentioned instead of ‘gross profit on sales’. Therefore paras 4 & 5 of the order are modified and substituted to read as under:-
“4. In this appeal we are concerned with the determination of Arm’s Length Price (ALP) in the auto components manufacturing segment. Pursuant to the order of the DRP, the only relief which the assessee seeks is with regard to the computation of profit level indicator (PLI) as done by the TPO which was operating
Corrigendum to IT(TP)A No.173/Bang/2022 Page 2 of 2 profit on total cost. The assessee seeks PLI to be gross profit on sales. No other grounds were addressed insofar as auto components manufacturing segment is concerned.
As far as prayer of the assessee for adopting PLI as GP/Sales is concerned, we notice that the coordinate bench of the Tribunal in assessee’s own case for AY 2010-11 in IT(TP)A no.485/Bang/2015 dated 18/05/2016 accepted the contention of the assessee and directed that the PLI should be adopted as GP/Sales. This is followed by the Tribunal for the AY 2011-12 also in assessee’s own case. The relevant observations of the Tribunal in assessee own case for the assessment year 2010-11 is reproduced below:-”
Except for the above modification, there is no other change in the order of the Tribunal dated 13.05.2022.