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TPO couldn't reject principle of aggregation accepted in earlier years without any change in circumstances

March 18, 2017[2017] 79 105 (Ahmedabad - Trib.)

IT/ILT : Where assessee sold a chemical product to AE as well as non-AEs and in order to arrive at ALP it aggregated all those transactions, since said method had been accepted in earlier years, in absence of any change in circumstances, TPO could not depart from same and made addition to ALP by adopting selling price to non-AEs as a valid internal CUP

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