If percentage of Commission earned from AE transactions is higher than AE transactions no addition can be made

Brief of the case: ITAT held in Sumitomo Corporation India Pvt. Ltd. Vs. DCIT that if the case of assessee was decided in the earlier assessment years and if the facts and circumstances were same as in the previous years ,then in the current year also same basis for assessment should be adopted. As in the above case, in the earlier assessment years the case of assessee was decided comparing the percentage of commission earned from non-AE transactions and AE transactions considering the same to be suitable appropriate internal comparable. So as in the current year also all the facts and circums...