Assessee-company is engaged in distribution and sale of cosmetic products.In order to benchmark its international transactions, assessee selected certain comparable.  TPO rejected certain comparables selected by assessee and selected one Meedicare Ltd  as comparable thereby making upward ALP adjustment. Tribunal held that Medicare Ltd  could not be considered as comparable entity. On appeal the Court held that  similar matter had been resolved inter parties for assessment year 2014-15 wherein Medicare Ltd  had been excluded from list of comparables to determine ALP and upward adjustments of income proposed had not been undertaken as well. Following the rule of consistency, the appeal of Revenue is dismissed.  (AY. 2019-10 to 2012-13