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2020 (6) TMI 101 - AT - Income TaxTP Adjustment - Selection of MAM - Addition of local trading segment of the cosmetic products - TPO Rejected TNMM method adopted by assessee and proceeded to adopt Resale price Method - HELD THAT:- As there is no change in the facts and circumstances of the case, the learned dispute resolution panel in assessee’s own case for assessment year 14-15 [2019 (4) TMI 1866 - ITAT DELHI] has also rejected Modi care Limited as comparable and accepted the transactional net margin method as the most appropriate method, we respectfully following the decision of the coordinate bench direct learned TPO to adopt transactional net margin method as the most appropriate method and also not to take Modicare Ltd as the comparable. Thus, we have held that transactional net margin method is the most appropriate method, the TPO is directed to examine the international transactions entered into by the assessee applying that method and compare the margin of the assessee with the comparable companies selected by the assessee.
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