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10. The next plea of assessee was that there was no merit in holding that trading activities of spares and trading of CBUs were two different activities and the two should be segregated and then proposed two to compare the gross profit margins of trading in spares to gross profit margins of CBUs, would mean rejecting the basic principle of functional analysis. The assessee also pointed out that in the activity of import and sale of CBUs, it was expected to earn lesser amount of gross profit as compared to the other activities, in which substantial asset cost and risk of assessee were involved. The assessee on without prejudice basis pointed out that separate Transfer Pricing Review Report submitted regarding the trading segment as a whole may be considered. The assessee also referred to objections raised against payment of royalty and rate to be charged and pointed out that payment of royalty was approved by RBI and Department of Industrial Policy and Promotion, Ministry of Commerce and Industry, Govt. of India and hence, the rate as agreed upon should be adopted.