Cost Plus Method accepted for arm's length pricing where prior years matched and no material factual difference was shown.

The Tribunal's acceptance of the Cost Plus Method for determining arm's length price of the assessee's international transaction was upheld because the Assessing Officer had accepted the same method in subsequent years and the Revenue failed to show any material factual difference for the year in question. On that basis, no substantial question of law arose, and the Revenue's challenge to the method was rejected.

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Issues: Whether the Tribunal was right in upholding the CIT(A)'s acceptance of the Cost Plus Method for determining the arm's length price in respect of the assessee's international transaction.

Analysis: The Tribunal accepted the Cost Plus Method for the assessee's purchase of raw materials. It also noted that the Assessing Officer had accepted the same method in the assessee's subsequent assessment years and the Revenue did not show that the facts for the present year were materially different. In these circumstances, no substantial question of law arose for consideration.

Conclusion: The Revenue's challenge to the acceptance of the Cost Plus Method was rejected.

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