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2020 (8) TMI 917 - AT - Income TaxTP Adjustment - selection of MAM - HELD THAT:- As decided in own case [2019 (12) TMI 1630 - PUNJAB AND HARYANA HIGH COURT] conclusion of the ITAT could not be faulted as the same was inconsonance with the provisions of the Act and the Rules. The contention of the Counsel for the revenue cannot be accepted as the Tribunal while upholding the TNMM Method has observed that the other methods prescribed under the Act namely the CUP or Cost Plus Method being not applicable in the facts and circumstances of the case, the Respondent Assessee could only resort to TNMM as the most appropriate method to show that its profit margin from international transactions was at arm’s length. As mentioned elsewhere, the facts of the years under consideration are identical to the facts considered by the co-ordinate bench and Hon'ble High Court in earlier A.Ys. Therefore, respectfully following the decision of the Hon'ble Punjab and Haryana High Court [2019 (12) TMI 1630 - PUNJAB AND HARYANA HIGH COURT] we decline to interfere with the findings of the ld. CIT(A). Accordingly, the grounds raised by the Revenue in both the A.Ys stand dismissed.
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