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2016 (4) TMI 209 - ITAT DELHI

2016 (4) TMI 209 - ITAT DELHI - [2016] 49 ITR (Trib) 435 - Penalty u/s 271(1)(c) - TPA adjustment - disallowance in the case of an assessee who has entered into an “international transaction” defined in Section 92B - Held that:- In the present case it is found that given the clear indication of compliances required by law, there is in fact a clear evidence that disclosures made by the assessee were in good faith and with due diligence and there is absence of wilful or malafide effort to conceal .....

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term interchangeably. However, in the present case the twin requirements of conjoint compliances presuppose that the two terms due diligence and good faith cannot be used interchangeably or independent of one another. Thus the acceptable standards laid down by the statute are that due and diligence efforts made by a prudent man in a given situation have also to be in good faith as all due diligent efforts per se may not be in good faith. Conversely an act done in good faith with honesty and sinc .....

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it must also act in good faith. The requirements are very stringent and required to be met scrupulously. In the facts of the present case, we find that the bonafide of the assessee cannot be doubted. To sum up it is seen that at the relevant point of the time when the TP Study was filed there was a debate on the issue of single year data and multiple year data. Considering the change of method from RPM to TNMM, we find that the assessee’s explanation that the method was changed from TNMM from 20 .....

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ot anticipate that despite there being only one segment, the TPO would still insist on holding that TNMM would be the most appropriate method relying on the past position where change in facts is an admitted position. The due diligence standards assiduously required to be adhered to in the present case are standards of reasonable and ordinary diligence. But extraordinary and extreme measures of care, caution and prudence insomuch as to anticipate a vigilance to the extent that despite a plausibl .....

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M By these two appeals filed by the Revenue the correctness of the consolidated order dated 20.12.2012 of CIT(A)-XX, New Delhi pertaining to 2006-07 and 2007-08 assessment years is assailed on the following grounds in the respective appeals:- ITA No.1062/Del/2013 1. On the facts and circumstances of the case and in law, the Ld.CIT(A) has erred in holding that it is not a fit case for imposition of penalty u/s 271(1)(c) thereby deleting the penalty of ₹ 1,16,74,768/- levied for assessment y .....

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the hearing. 2. The relevant facts of the case relatable to the issue are that the assessee i.e. Boston Scientific India Pvt. Ltd. (previously known as Guidant India Private Limited) is a company incorporated under the Indian Companies Act, 1956 in July 2003. It is stated to be primarily engaged in promotion, marketing, sales and distribution in India of a wide range of cardio-vascular products and related medical instruments and equipments manufactured by the Boston group. The assessee is also .....

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ideration. The assessee was found to have used Resale Price Method (hereinafter referred to as RPM ) as the most appropriate method and had selected 6 comparable companies in its Transfer Pricing study (hereinafter referred to as TP study ). 3.1. The methodology adopted by the assessee was rejected by the TPO following the methodology accepted in assessee s case for 2005- 06 AY holding that the Most Appropriate Method (hereinafter referred to as MAM ) would be Transactional Net Margin Method (he .....

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dered to be the most appropriate method. Accordingly it justified its selection of using RPM as the most appropriate method for its distribution segment . 3.1.2.The explanation in support of the change of method offered by the assessee was not accepted by the TPO. 3.1.3. Further considering the 6 comparables offered by the assessee in its TP study, the TPO rejected 3 comparables. Retaining the remaining 3 comparables out of these 6 offered, he further required the assessee to conduct a fresh sea .....

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taking TNMM as the MAM for similar reasons as in the immediately preceding assessment year. 3.2.1. Out of the total 9 comparables offered by the assessee, the TPO rejected 3 comparables retaining 6 comparables offered by the assessee. 3.2.2. He further also rejected the multiple year data and using single year data for the 6 comparables retained proposed an addition of ₹ 1,52,93,937/- by way of adjustment in the international transaction of the assessee. 3.3. In both the years, the assesse .....

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t the addition was accepted as the company wanted to do away with unnecessary litigation. 4.1.1. It was also pleaded that due taxes on the additions were promptly paid proved it s bona fide. 5. Similar submissions were offered in the penalty proceedings in A.Y.2007-08 through letter dated 19.07.2011 before the AO (copy at page no.114 of the paper book). 6. Not convinced with the explanation offered, the AO held that the assessee s explanation could not be accepted on the following grounds:- (i) .....

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hat it had not supplied/furnished any inaccurate particulars of income; (b) nor it had concealed any particulars of income; and (c) it was a mere case of rejection of a claim made by the assessee for which no penalty could be levied. 7. Aggrieved by the penalty order, the assessee came in appeal before the CIT(A). Apart from re-iterating the arguments advanced before the AO, various other arguments were also raised assailing the action including (a) justification for the change of most appropria .....

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this, the Revenue is in appeal before the ITAT in both the years. 10. The Ld. CIT DR placed heavy reliance on the penalty order. Further attention was invited to the TPO s order in both the years. It was submitted that in view of the following specific factual shortcomings pointed out by the TPO the assessee was required to bring out the circumstances which warranted a change and was also further required to submit why TNMM should not be used. It was submitted that in regard to the issues nothin .....

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ed in transfer pricing report, the assessee i.e. Guidant India has been classified as a distributor which carries out marketing, promotion, sales and distribution of Guidant products in India. The assessee is a 100% subsidiary distributor of its AE. The financials of the assessee including P&L account were examined. It was found that the assessee in the current year had incurred a loss of ₹ 79.05 lacs on a turnover of ₹ 37.61 Crs. As compared to this, the assessee had shown a pro .....

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s changed the method of benchmark international transactions from TNMM used last year to Resale Price Method (RPM). The assessee was asked to state the change in circumstances that have warranted change in comparability method. The assessee was also asked to state as to what was the difference in the international transaction as compared to last year. The assessee was asked to show cause as to why TNMM method should not be used to benchmark international transactions in this year also on account .....

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ethodology has been given up by the assessee itself nothing further remains for the Revenue to show that it is a case of filing of inaccurate particulars and concealment. 10.2. The CIT DR also submitted that the assessee had significant expenses pertaining to discounts and rebates and also advertisements and sales expenses. It was argued that had the claim of the assessee been bonafide, it would have atleast made adjustment for these expenses which is not a fact. The said argument of the Ld. CIT .....

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271(1)(c). It was submitted in support of the prayer that there was sufficient judicial precedent to allow the prayer of the Revenue and the Tribunal can consider the issue taking the correct Explanation on record while deciding the issue. It was submitted that the Courts have repeatedly held that where the AO has wrongly invoked section 68 in place of sections 69, 69A, 69B or 69C etc. the order does not become bad merely because a wrong section has been quoted and the issue can still be consid .....

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Jeevan Lal Shah (1994) 205 ITR 244 (SC), it was his submission that penalty imposed deserved to be upheld in both the years. 11. The Ld. AR heavily relying upon the impugned order invited specific attention to the facts recorded by the CIT(A) in paras 4.1 to 4.4 of his order. Since it is a consolidated order for both the years under consideration, heavy reliance was placed thereon. It was his submission that in both the years the assessee vide letters dated 10.06.2010 and 19.07.2011 in the two .....

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d only one segment i.e. distribution of medical equipment and it was considered that on account of the peculiarities of this segment RPM was the MAM. It was submitted that no doubt the method adopted by the assessee in the earlier years was TNMM but this was on the ground that then it admittedly had two business segments namely marketing support services segment and also the distribution segment . Thus TNMM was considered to be the most appropriate method. It was clarified that the medical equip .....

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on. It was submitted that on perusal of the same it can be seen that whatever method is used in the two years the results would clearly demonstrate that no case for penalty is made out. 11.4. It was his submission that even when considering the issue in the light of the requirements of Explanation 7 to section 271(1)(c) it can be concluded that the assessee has acted all along in good faith with due diligence which are the requirements incorporated in Explanation 7 to sec.271(1)(c). 11.5. It was .....

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07 AY, considering the six comparables offered no adjustment would be warranted. This fact it was submitted is evident from the table 2 in para 5.1.5 of the impugned order. 11.7. Similarly in 2007-08 AY it was submitted if Table 3 in the same para of the CIT(A) s order is considered it would show that whatever method is considered the margin would be within +/- 5%. 11.8. It was also his submission that the arguments of the Ld.CIT DR that the assessee had marketing intangibles is of no relevance. .....

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nal units Recharges from/to Group Cos. Resale Price Method ('RPM') Gross Profit/Sales ('GP/Sales') 39% 21% Receipt of IT Services Comparable Uncontrolled Price Method (CUP) N.A. Refer Paras 1.4.1 to 1.4.3 below Refer paras 1.4.1 to 1.4.3 below Reimbursement of expenses CUP N.A. Refer para 1.5.1 below Refer para 1.5.1 below 11.9. Referring to the said order it was submitted that the TPO had addressed and quashed only the purchase of finished products and equipments and therein als .....

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of the requirements of Explanation 7 to section 271(1)(c) has already been addressing by the CIT(A) who has examined the provisions before quashing the penalty. Heavy reliance was placed on the findings. 12. The Ld. CIT DR inviting attention to the reply of the assessee before the TPO in para 5.1.6 & 5.1.8, submitted that if RPM method was the MAM according to the assessee then adjustments for the discounts and rebates and advertisements expenses on facts should have been made by the assess .....

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can only rely for facts on the case made out by the TPO and as the TPO has accepted the assessee s Transfer Pricing Report and has merely changed the most appropriate method and reduced certain comparables offered by the assessee and accepted the further introduction of three more comparables in one year again offered by the assessee it was submitted that now the CIT DR cannot make out a new case. It was also his argument that even otherwise the Hon ble Delhi High Court in the case of Sony Eric .....

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lanation 7 of section 271(1)(c). Thus noting that the request was not opposed on behalf of the assessee, we allow the prayer of the Ld.CIT DR in the peculiar facts and circumstances of the case that the issues be considered in the light of Explanation 7 to section 271(1)(c) instead of Explanation 1 of section 271(1)(c). 13.1. The relevant provisions of section 271(1)(c) are set out hereunder for ready-reference:- 271(1). If the [Assessing] Officer or the [Commissioner (Appeals) [or the [Principa .....

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r sub-section (4) of section 92C, then, the amount so added or disallowed shall, for the purposes of clause (c) of this sub-section, be deemed to represent the income in respect of which particulars have been concealed or inaccurate particulars have been furnished, unless the assessee proved to the satisfaction of the Assessing Officer or the Commissioner (Appeals) [or the [Principal Commissioner or] Commissioner] that the price charged or paid in such transaction was computed in accordance with .....

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deemed to represent such income in respect of which particulars have been concealed or inaccurate particulars have been furnished. The caveat or exception being carved out only in the case where the assessee proves that the price charged or paid in such transaction was computed in accordance with the provisions contained in section 92C; and in the manner prescribed under that section in good faith and with due diligence. 13.3. Thus in order to consider whether the said requirements of Explanati .....

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olis, USA. It is the ultimate parent of all Guidant group companies across the world. It is primarily engaged in the development, manufacturing and marketing of a broad array of products and service for cardiac and vascular patients. Its Indian operations are carried out on by Guidant India, a wholly owned indirect subsidiary. 2.2. Group companies own significant valuable intellectual property rights and other commercial or marketing intangibles and are involved in complex product development, m .....

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d utilize routine tangible assets. 13.5. On consideration of facts which have been addressed in the earlier part of this order elaborately it is evident that it is undisputed that the most appropriate method selected by the assessee was varied by the TPO after giving the assessee a reasonable opportunity of being heard. It is seen that the assessee had raised various arguments opposing the change of method and defended unsuccessfully before the TPO the method adopted in its TP study. It is also .....

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ssee was directed to carry out a fresh search using single year data and out of this search carried out by the assessee three other comparables offered by the assessee were accepted during the assessment proceedings. In the second year i.e. 2007-08 AY, nine comparables were offered by the assessee using the multiple year data and three comparables were excluded by the TPO thus retaining the six comparables offered by the assessee using single year data the additions have been proposed. 13.6. We .....

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accepted by him has not been either assailed before us or rebutted by the Revenue by any argument or contrary evidence. For readyreference, we extract the relevant para from the order hereunder:- 5.1.5 . In order to prove the good faith and due diligence , the appellant had pleaded that even if the same original 6 comparables are taken with a single year data in the AY 2006-07, the appellant s international transaction is at arm s length in either of the methods i.e. RPM or TNMM. The same is de .....

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that the margin of the appellant will fall within +/- 5% by using the same set of 9 comparables used in the TP study with current year data in both the methods:- For AY 2007-08 TNMM RPM S. No. Name of the Comparable OP/Sales (%) GP/Sales (%) 1. Abott India Ltd. 13.50 32.81 2. Advanced Micronic Devices Ltd. 10.15 47.62 3. BA & Brothers (Eastern) Limited 2.64 9.67 4. Bijoy Hans Limited -68.89 6.25 5. Hemant Surgical Inds Ltd. 3,73 10.24 6. Mark remedies Ltd. Date Not available Data Not availa .....

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back is deemed to represent the income in respect of which particulars have been concealed or inaccurate particulars have been furnished. The rigours of the penal action would not be attracted if the assessee can demonstrate that the price charged or paid in such transaction was computed in accordance with the provision contained in section 92C and in the manner prescribed under that section in good faith and with due diligence (emphasis provided) . 13.7.1. Thus, we find that the law as it stan .....

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ly maintained that the change was effected in view of the fact a particular segment was discontinued in the year under consideration and for the distribution segment, RPM was considered to be the most appropriate method. Notwithstanding the fact that the explanation was not accepted and the issue was given up by the assessee for the stated reasons of avoiding litigation the fact remains that the merits of the explanation in the penalty proceedings has to be considered independently. The mere fac .....

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argument has been made that in the year under consideration there was only one segment i.e. distribution segment as opposed to another segment i.e. of marketing service segment which was the position in 2005-06 AY wherein TNMM had been selected in a matter of record. The argument on facts is found to be correct. Whether the said fact can be said to be so persuasive as to lead only to the inference that the exercise was in good faith following the due diligence standards set out by the statute a .....

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o question negligence where due diligence standards are required to be met negligence cannot be tolerated. Similarly due diligence standards may not necessarily be embedded with good faith. 13.8.3. Thus the law requires that the standards to be met by a taxpayer pleading that penalty is not leviable in situations where Explanation 7 is attracted has been kept very high. The twin requirements of the Act may be capable of being summed up in the term best efforts which not only presuppose due dilig .....

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of the prescribed methods to be followed in certain circumstances. Thus when the conduct of the assessee in using this method in the year under consideration is considered alongwith the justification for selecting this method namely having only one segment i.e. the distribution segment in the year consideration as opposed to the earlier factual position the explanation is plausible and acceptable and unless rebutted by some fact or argument to the contrary. The assessee is presumed to have disc .....

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relying on facts and law in support of its selection of method the onus shifts to the Revenue to demonstrate that even on following the best efforts, the said method could never have been selected i.e. the due diligence requirements and good faith requirements were breached due to the active selection of this method. No such argument has been raised before us. Thus in the context of these cumulative facts and legal position, we find that the explanation offered qua the change of method, when re .....

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in offering the comparables the best efforts practices were followed by it, as the due diligence standards and good faith standards requirement qua the said issue also needs to be met. It is a matter of record that in both the years under consideration the additions are based on the comparables offered by the assessee. Not even one comparable has been introduced by the TPO. The fact that all the comparables offered were not accepted by the TPO in both the years or alternatively the TPO has parti .....

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troduced by the TPO itself leads to the conclusion that due diligence has been exercised in good faith by the assessee in selecting the comparables. This argument has been accepted by the CIT(A). On examining this grievance of the Revenue, we find that just because certain comparables were excluded by the TPO, the claim of exercise of due diligence and good faith in selecting the comparables offered does not get eroded unless the same was rebutted by the Revenue by showing specific instances exp .....

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TP study placed on record in 2006-07 and 2007-08 AYs by the assessee. On a consideration of the jurisprudence available thereon, we find that even on this ground the claims of exercise of due diligence and good faith by the assessee in computing the TP study in accordance with the provision of section 92C is not eroded. The conclusion is supported by the decision of the Co-ordinate Bench dated 17.09.2012 in ITA No.5566/Del/2011 in the case of M/s Verizon Communication India P. Ltd. vs DCIT where .....

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isions there was a legal debate as to whether multiple year data could be used or only the current year s data. The decision of the Co-ordinate Bench considering that the case of the assessee pertained to 2006-07 AY concluded that in 2006 when the assessee completed its Transfer Pricing Study and filed its return the debate was very much alive. Accordingly it was held that penalty levied on that count cannot be sustained. On considering the facts in the present case, we find that one of the year .....

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er to defraud the Revenue. As single year data at the behest of the TPO was provided and due taxes on the adjustments made were paid promptly the only conclusion that could be drawn in the peculiar facts and circumstances of the case is that the use of multiple year data was done with due diligence and in good faith as till 2007 the issue was debatable. 13.11. It is even otherwise evident from the record that even before the CIT(A) the assessee has argued in support of its claim of good faith an .....

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is further seen that considering the facts of the present case that the CIT(A) has himself examined the legal position. The CIT(A) has examined the issue in the light of Explanation 7 to Section 271(1)(c) of the Act. Reliance has been placed upon the order of the ITAT in the case of CIT(A) vs RBS Equities India Ltd. in ITA No.4654/Mum/2009 order dated 26.08.2011 considering the facts of that case, where the said assessee i.e. RBS Equities India Ltd. had entered into International transaction wit .....

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e. change of method herein from RPM to TNMM and therein from CUP to TNMM it has been held to be a bonafide difference of opinion. Relying upon the following extract of the decisions of the Apex Court in the Reliance Petro Product Ltd. 322 ITR 158 (SC), it was held that there was no case of levy of penalty as the assessee could not be expected to visualise the invoking of different method by the TPO in valuing the international transaction as the basic data furnished by the assessee was not fault .....

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held guilty of furnishing inaccurate particulars. In order to expose the assessee to penalty, unless the case is strictly covered by the provision, the penalty provision cannot be invoked. By no stretch of imagination can making an incorrect claim tantamount to furnishing inaccurate particulars. There can be no dispute that everything would depend upon the return filed by the assessee, because that is the only document where the assessee can furnish the particulars of his income. When such part .....

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ng inaccurate particulars regarding the income of the assessee. Such a claim made in the return cannot amount to furnishing inaccurate particulars. 13.14. No doubt when there is a difference between the assessed income and the returned income, a presumption of concealment or furnishing of inaccurate particulars of income or both can be raised and the onus is on the assessee to explain the difference. However the mere fact that the addition is accepted per se does not mandate that penalty is levi .....

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e transaction can be shown to be computed without due diligence with wilful attempt to defraud the Revenue. It is also a settled legal position that wherever there is a debate on the issue and two views are possible the bonafide of an explanation in having followed one of the views cannot be a ground for levying penalty.. 13.15. As we have already individually addressed each of three issues arising in the present facts of the case it is found that in the event of an addition or disallowance by t .....

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nd with due diligence is used in Explanation 7 of section 271(1)(c) as a hyphenated phrase which looses its essential meaning of the individual words when considered separately as abstract phrases. Good faith alongwith due diligence presupposes true and fair presentation which is not misleading, ambiguous or obscure. Given the clear indications of law that the price charged or paid in such international transaction (or specified domestic transactions with which we are not concerned in the presen .....

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that disclosures made by the assessee were in good faith and with due diligence and there is absence of wilful or malafide effort to conceal and defraud the Revenue. Due diligence presupposes making all possible efforts/endeavours which a prudent man would have done in the given circumstances or a process whereby one gathers facts to make an informed choice on a matter. Good faith on the other hand is an abstract and comprehensive term. It requires that the action should be honest and encompasse .....

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o to be in good faith as all due diligent efforts per se may not be in good faith. Conversely an act done in good faith with honesty and sincerity per se is not sufficient as acts done in good faith protects acts of negligence. However, the act of computing a transaction is to be done with due diligence i.e. strictly in accordance with the provisions contained in section 92C and in the rules framed there under and thus necessarily in the manner prescribed therein while so computing no negligence .....

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ata. Considering the change of method from RPM to TNMM, we find that the assessee s explanation that the method was changed from TNMM from 2005-06 AY to RMP in 2006-07 & 2007-08 AY on the ground that there was only one segment in the year and accordingly the most appropriate method selected was the RPM. Notwithstanding the fact that the said approach was not approved by the TPO, it does not detract from the plausible claim that in view of only one segment i.e. the distribution segment the me .....

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