TPO made transfer pricing adjustment in respect of Transport segment. DRP upheld order of TPO. Tribunal held that findings returned by TPO who found that there was no internal comparable under Segment-A, being, Transport segment and assessee’s application of PLI given in Segment-C relating to Refrigeration (non-AE) segment was not acceptable. Assessee’s application for additional evidence including expert technical opinion provided by assessee and report of Valuation Officer need to be examined at end of TPO/AO on facts relevant for year under consideration. Accordingly the order was set aside and matter remitted to file of AO/TPO for deciding issue afresh in light of additional evidence. (AY.2005-06, 2009-10 to 2013-14)