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TP method consistently followed by assessee can't be changed by TPO if there is no change in circumstances

March 5, 2019[2019] 102 438 (Mumbai - Trib.)

IT/ILT: Where TPO had changed over to CUP method as MAM by rejecting TNMM method consistently being applied by assessee without any change in facts and law, adjustment made by TPO was to be set aside

IT/ILT: Where entities are operating in different geographical, political and economical environment, same have to be taken into account for benchmarking comparable transactions and TNMM would be MAM in such case

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