S. RAVINDRA BHAT, J.

1. These two appeals by the assessee require resolution of common questions of law and arise from identical or closely similar circumstances. The questions of law framed in these appeals, on 17.10.2014, are as follows:

1. Whether the Transactional Net Margin Method adopted by the assessee is the most appropriate method envisaged under Section 92C(2) of the Income Tax Act, 1961 read with Rule 10C of the Income Tax Rules, 1962 and whether the Income Tax Appellate Tribunal had erred in directing the Assessing Officer to apply Comparable Uncontrolled Price Method?

2. Whether there is a contradiction in the order of the Income Tax Appellate Tribunal as it has directed that the Transfer Pricing Officer should apply Comparable Uncontrolled Price Method?

2. The appellant assessee is engaged in manufacturing and sale of auto electrical products such as Starters, Alternators, Wiper Motors, CDI, Magnetos etc., for four wheel and two wheel vehicles. Its promoters include two Japanese Companies, which are M/s Denso Corporation, Japan and M/s Sumitomo Corporation, Japan. These promoters’ share holding is to the extent of 47.93% and 10.27% respectively. M/s Sumitomo Cor