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3. This appeal was ADMITTED on 23.11.2015 to consider the aforesaid substantial questions of law framed by the learned counsel for the Appellants-

Revenue.

4. The learned Tribunal, after discussing the rival contentions of both the appellants-Revenue and the Respondent-assessee, has returned the findings as under:

"41. We have given a very careful consideration to the rival submissions. On the issue as to whether the international transactions have to be considered separately or independently without aggregating them as part of the segment to which they relate, we find that the term 'international transaction' has been defined in section 92B of the Act to mean and include transactions between two or more AEs, Date of Judgment 13-07-2018 I.T.A.No.525/2014 The Commissioner of Income-tax & Anr. Vs. M/s. Toyota Kirloskar Motors (P) Ltd., either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money or any other transaction having bearing on the profits, income, losses or assets of such enterprise. Section 92 of the Act provides that income from international transactions between AEs shall be computed having regard to ALP. Section 92-C of the Act prescribes the method s of determining ALP, having regard to the most appropriate method which will be decided in accordance with the rules prescribed. Rule 10A(d) of the Income-tax Rules 1962 ['the Rules'] provides that 'transaction' would include a number of closely linked transactions. Rule 10B(1)(d) of the Rules advocate profit split method of determining ALP where international transactions involve transfer of unique intangible or in multiple international transactions which are so inter-related that they cannot be evaluated separately for the purpose of determining ALP of any one transaction. It thus appears that the Act and the Rules contemplate determining ALP by aggregating international transactions which are multiple, interlinked or inter-related to each other and cannot be evaluated separately. To this extent the conclusions of the TPO regarding determination of ALP by taking segmental results without looking into as to whether Date of Judgment 13-07-2018 I.T.A.No.525/2014 The Commissioner of Income-tax & Anr. Vs. M/s. Toyota Kirloskar Motors (P) Ltd., the two segments are interlinked or inter-related cannot be sustained. As to what would be the most appropriate method in such cases is again dependent on Rules 10B(2) and (3) of the Rules.