Change in method of ALP in transfer pricing adjustment not permitted on same set of facts

Brief of the Case ITAT Pune held In the case of M/s. Vishay Components India Pvt. Ltd. vs. ACIT that where the revenue from year to year has accepted the method adopted by the assessee for benchmarking its international transactions with its associate enterprises, in the absence of any reasons brought on record, there is no merit in deviating or taking stand contrary to the stand accepted in both the preceding and succeeding years. It was held that for benchmarking international transactions with its associate enterprises on aggregate basis, TNMM method should be applied and since the margins ...