Company (India) Private Income Tax9(2)(2), Limited Room No.203, Aaykar th 604, Delphi, B Wing, 6 Bhavan, M.K.Road Floor, Hiranandani Business Mumbai 400 020 Park, Hiranandani Gardens, Powai, Mumbai 400 076 PAN/GIR No.AAACE1260B (Appellant) .. (Respondent) Assessee by Shri Dhanesh Bafna / Shri Pratik Shah & Shri Nishant Shah Revenue by Shri Manjunath K Date of Hearing 08/05/2019 Date of Pronouncement 14/06/2019 आदे श / O R D E R PER M. BALAGANESH (A.M): These appeals in ITA Nos.6098/Mum/2018 & 531/Mum/2018 for A.Y.201415 & 201314 respectively arise out of the order by the ld. Joint Commissioner of Income Tax (TP)2(1), Mumbai in appeal dated 27/10/2017 & Joint Commissioner of IncomeTax (TP)2(1), Mumbai (ld. CIT(A) in short) against the order of assessment passed u/s.143(3) of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 27/09/2018 by the ld. Asst. Commissioner of Income Tax 9(2)(2), Mumbai (hereinafter referred to as ld. AO). Since identical issues are involved in 2 ITA Nos.6098/Mum/2018 & 531/Mum/2018 M/s. Emerson Electric Company (India) Pvt. Ltd., these appeals, they were heard together and are being disposed off by this consolidate order, for the sake of convenience. With the consent of both the parties, the appeal in ITA No.6098/Mum/2018 for A.Y.201415 is taken up for adjudication first. 2. The ground No.1 raised by the assessee is general in nature and does not require any specific adjudication. 3. The brief facts of the assessee are that the assessee filed its return of income for A.Y.201415 on 30/11/2014 declaring total income of Rs.155,49,76,710/. The assessee company i.e Emerson Electric Company (India) Private Limited ('Emerson') is in the business of providing engineering support services including configuration engineering, framework design and graphical design, largely in connection with industrial automation projects undertaken by other Emerson group members. Emerson also provides IT services including database administration and help desk support to various members of the Emerson group. Emerson also maintains manufacturing and distributions operations. Emerson conducts its business through following segments: a) Manufacturing segment This segment is engaged in trading of tools which are used in elevator applications. b) Distribution segment This segment is engaged in importing ultrasonic welding and cleaning equipment and accessories from group companies and selling them in local market. 3 ITA Nos.6098/Mum/2018 & 531/Mum/2018 M/s. Emerson Electric Company (India) Pvt. Ltd., c) Engineering and related services segment This segment is engaged in rendering designing and other engineering development needs with respect to products sold by the Emerson group. d) IT and related services segment (ITeS segment) This segment is engaged in rendering services related to IT help desk and database administration related services. e) Software development and related service segment (IT segment) This segment is engaged in software development related services which are used for manufacturing microprocessors by Emerson group. f) Facilitation support service segment (MSS segment) This segment is engaged in rendering marketing support services in respect of products of the Emerson group 3.1. Pursuant to the directions of ld. DRP, the ld. AO passed the final assessment order by making adjustment to arm‟s length price (ALP) on account of the following items to the tune of Rs.20,62,58,915/ as under: S.No. Description Amount in Rs. 1 Adjustment on account of provision of engineering and related 12,36,14,584 services 2 Adjustment on account of provision of ITeS 6,03,56,767 3 Adjustment