JUDGMENT 1. This Appeal under Section 260-A of the Income Tax Act, 1961 (the Act), challenges the order dated 30th January, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). The common impugned order dated 30th January, 2015 disposes of the appeal, relates to Assessment Years 2005-06, 2006-07 and 2007-08. This appeal is in respect of Assessment Year 2005-06. 2. Revenue urges the following re-framed question of law, for our consideration: " Whether on the facts and in the circumstance of the case and in law, the Tribunal was correct in law in holding that the two segments viz: manufacturing and trading are comparable to determine the Arms Length Price (ALP) of the trading goods exported to Associated Enterprises (AE)?" 3. The Respondent-Assessee is engaged in manufacture of carburettors and Air Suction Valves (ASVs) [finished goods] used in the manufacture of motorcycle and other two wheelers. The Respondent is also engaged in trading activity of selling parts and components (parts) of finished goods, which are used in its manufacture. The sales of finished goods in the domestic market is 97% of its total sales and balance 3% is of its sales, is of parts. 4. The Respondent-Assessee sell its parts in the international market to its Associated Enterprises (AE). The Respondent-Assessee adopted the Transaction Net Margin (TNM) Method as most appropriate method to arrive at the Arms Length Price (ALP) of its transactions with AE. The Transfer Pricing Officer (TPO) while accepting the TNM method as the most appropriate method, bench marked the net margins derived from export of parts (trading activity) with the net margins derived from domestic sales. This, resulted in an addition of Rs. 62.72 lakhs in the Assessment Order dated 2nd February, 2009. 5. Being aggrieved with the order dated 2nd February, 2009, the Respondent-Assessee filed an appeal to the Commissioner of Income Tax (Appeals) [CIT(A)]. By an order dated 30th January, 2015 the CIT(A) allows the Respondent-Assessee''s appeal, by holding that, it was incorrect to benchmark its margins from export of parts with margin in domestic sales of all its goods which consisted primarily of manufactured finished goods i.e. to the extent of 97% of total sales. Besides, the CIA(A) found that the internal comparable, if any, should have been with profits derived from sale of parts alone. Thus, CIT(A) while allowing the appeal, deleted the addition of Rs. 62.72 lakhs. 6. Besides, the CIA(A) found that the internal comparable, if any, should have been with profits derived from sale of parts alone. Thus, CIT(A) while allowing the appeal, deleted the addition of Rs. 62.72 lakhs. 6. Being aggrieved with the order dated 30th January, 2015 of the CIT(A), the Revenue filed an appeal to Tribunal. On examination of facts, the Tribunal further found that there was difference in the nature of customers in the domestic and export market. The impugned order on FAR (Functions, Assets & Risks) analysis found that export of parts which go into the manufacture of finished goods, were not comparable with the finished goods. Thus, dismissed the Revenue''s appeal. 7. Being aggrieved with the order of t he Tribunal, the Revenue is in appeal before us. Mr. Suresh Kumar, reiterates the Assessment Order dated 2nd February, 2009 and the order dated 28th March, 2008 of the TPO. 8. We find that both the CIT(A) and the Tribunal, on facts, had found that the margins derived on export of parts to AE, are not comparable with the margins derived from sales made in the domestic market. This is primarily because the margin derived in the domestic market is on account of sales of finished goods to the extent of 97%. Besides, on facts, it was found that not only the parts and finished goods are not comparable, but the class of customers to whom they sold are also different. This resulted in difference as found on FAR analysis. The above concurrent finding of fact is not shown to be perverse in any manner. 9. Therefore, in view of the above concurrent finding of fact, the question as framed does not give rise to any substantial question of law. 10. Accordingly, Appeal dismissed. No order as to costs.