On appeal it was held that, Tribunal was justified in applying TNMM on the aggregated transactions of import of finished goods for resale and export of finished goods to AEs, observing that TNMM has been consistently applied over the years and also because Revenue has not been able to show any material difference in the subject assessment year which would justify a change in the most appropriate method (TNMM) adopted while benchmarking the international transactions (ITA No. 1643 of 2016 dt. 18-02-2019) (AY. 2005-06)
PCIT v. Vishay Components India (P) Ltd. (2019) 307 CTR 744 / 176 DTR 46 (Bom.)(HC)
S. 92C : Transfer pricing-Arms’ length price-Most appropriate method vis-a-vis rule of consistency-TPO applied the RPM and CPM method for benchmarking international transactions- Tribunal however applied TNMM on the aggregated transactions observing that it has been consistently applied over the years-Justified.