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2019 (9) TMI 1679 - ITAT DELHITP Adjustment - Selection of MAM - rejection of the Cost Plus Method (CPM) adopted by the assessee as the Most Appropriate Method for determination of the Arm’s Length Price (ALP) and applying TNMM as the Most Appropriate Method with OP/TC as PLI - HELD THAT:- In the absence of any change in the facts and circumstances of the case, we are of the considered opinion that the rule of consistency demands that the consistent view has to be taken. We, therefore, while respectfully following the decision of the Hon’ble Apex Court in the case of Radhasoami Satsang [1991 (11) TMI 2 - SUPREME COURT] accept the consistent view taken in assessee’s own case for the earlier as well as the subsequent year and hold that CPM is the most appropriate method for the determination of ALP in this case. In view of this conclusion reached by us, it is not necessary to consider the suitability of M/s Kerala Travels Interserve Ltd. Grounds of appeal of the assessee are allowed accordingly. Appeal of the assessee is allowed.
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