The assessee was operating in two segments, manufacturing and trading. The TPO examined the two segments separately and made a transfer pricing addition. The ITAT held that the two segments should be combined and then analyzed for determining the ALP of the transactions. Accordingly, the matter was remanded to the AO/ TPO. The assessee challenged the order of the ITAT on the ground that the remand was an academic exercise. Rejecting such contention, the High Court noted that the Tribunal has directed the two segments to be analyzed on a combined basis and the same cannot be called an academic exercise. Therefore, assessee’s appeal was dismissed. (AY. 2008-09)