under:
Manufacturing Segment:
SI .
No. Comparables' Name Sales OP OC OP/OC OP/Sales
1 Amtech Power ... Trading Segment:
Sl
Company Name Sales OP OC OP/OC OP/Sales
No
1 Cuprum Bagrodia
Operating
Profit ("OP")/Total Cost ("TC") as the Profit Level Indicator
("PLI") instead of OP/Sales without providing ... objection was related to the TPO considering
OP/TC as the PLI instead of OP/ Sales taken by the assessee without
providing any reason
considering Operating
Profit ("OP")/ Operating Cost ("OC") as the PLI instead of OP/ Sales with
respect to the manufacturing segment, without ... manufacturing sales to
total sates less than 25% were selected
IV. Trading sales filter: Companies with trading sales more than
75% of total sales were
decision of Supreme Court in the case of Totgars Co-
op. Sale Society Ltd. v. ITO [2020] 188 Taxman 282 (SC), the above
interest income ... thereafter relying on the decision of Supreme Court
in Totgars Co-op. Sale Society Ltd. (supra) held that AO ought to have
taxed the interest
profit margin of 29.30% which is
as follows:
SI. Company Name Sales OP to
No (Rs.cr.) Total
. Cost%
1 Lanco Global Systems ... chose 4 comparable companies
which were as follows:
Sl. Company Name Sales OP to RPT % of RPT Expor % of Data
No (Rs.cr Total
Apex Court
rendered in the case of Totgar's Co-op Sale Society Ltd. as reported in 322 ITR
283 (SC) and decided ... Apex Court in the case of Totgar's Co-op Sale Society Ltd. (supra), it was
submitted that on this issue, there
2016) and taxing the same. The
said citation of Totgars Co-op. Sale Society Ltd. relied upon
by the Respondent is inapplicable to the appellant ... case. It
is submitted that in Totgars Co-op. Sale Society Ltd., the
Hon'ble Apex Court as well
categorical pronouncement in the matter of Pr. CIT
versus Totgars Co-op Sale Society [395 ITR 611] , wherein after
taking into account the judgment ... jurisdictional High Court in
the matter of Pr. CIT . Totgars Co-op Sale Society [(2017) 392 ITR
74W], wherein at para 10, it was held
sale 36847765
of assets)
Operating Profit (PBIT) 785989
OP on cost 2.13%
OP on sales 2.09%
The segmental results in respect of its trading segment ... Crore)
Sl Company Finance Adj. Net Adj. Op. Adj. Op. Adj.
No Name Year Sales Cost Profit OP
/Sales
1 Ashok
decision of
Hon'ble Supreme Court and Totagars Co-op. Sale Society, 322 ITR
282 (SC) and Hon'ble Karnataka High Court ... Citizen Co-op. Society as well as
decision of Hon'ble Karnataka High Court in the case of Totagars Co-
op. Sale Society
