TPO couldn’t choose Cost Plus Method to fix ALP if there was functional differences in export and do

IT/ILT : Where assessee was engaged in business of manufacture and sale of industrial products such as decanters, separators etc. to its AE located abroad as well as in domestic sector, in view of fact that there were various differences in export segment and domestic segment such as market functions, geographic difference, volume difference, credit risk, related party transactions etc., TPO was not justified in adopting CPM as most appropriate method in order to make adjustment to assessee's AL