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AO had to show difference in facts in order to reject TNMM which was consistently followed in previous years

April 3, 2019[2019] 103 421 (Bombay)

IT/ILT : Where TNM method is accepted to determine ALP of international transaction and, no change in facts has been asserted by assessee, it would be for revenue to show difference in facts warranting a different view in this assessment year to that taken in subsequent assessment years

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