Assessee was engaged into manufacturing and trading of light commercial air-conditioning systems. The assessee applied other method by considering gross margin of comparable companies with gross margin earned by it. TPO applied TNMM  and made addition. On appeal the Tribunal held that relevant year was first year of manufacturing undertaken by assessee and it had been constantly following other methods in succeeding years which had been accepted by TPO. Following the  rule of consistency matter remitted back to TPO to decide afresh as to whether other method  applied by assessee was MAM.  (AY. 2013-14)