https://www.taxtmi.com/caselaws?id=760495 HC dismissed Revenue's appeal regarding TP adjustment for AY 2005-06. Assessee used RPM with gross profit to sales ratio as PLI, while TPO applied TNMM in both AY 2004-05 and 2005-06. Revenue failed to demonstrate material factual differences between the two assessment years that would justify different treatment. ITAT correctly followed precedent from AY 2004-05 case. TPO had rejected RPM and foreign associated enterprise as tested party in both years, with CIT(A) concurring on TNMM methodology. Revenue could not establish grounds for distinguishing the current year from previous decision. en-us Tue, 15 Oct 2024 00:00:00 +0530 Tue, 10 Jun 2025 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760495 HC dismissed Revenue's appeal regarding TP adjustment for AY 2005-06. Assessee used RPM with gross profit to sales ratio as PLI, while TPO applied TNMM in both AY 2004-05 and 2005-06. Revenue failed to demonstrate material factual differences between the two assessment years that would justify different treatment. ITAT correctly followed precedent from AY 2004-05 case. TPO had rejected RPM and foreign associated enterprise as tested party in both years, with CIT(A) concurring on TNMM methodology. Revenue could not establish grounds for distinguishing the current year from previous decision. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760495