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Sec. 92C of Income Tax Act, 1961—Transfer Pricing— It is a well settled legal position that factual matters which permeate through more than one assessment year, if the Revenue has accepted a particular view or proposition in the past, it is not open for the Revenue to take an entirely contrary or different stand in a later year on the same issue, involving identical facts unless and until a cogent case is made out by the TPO/Assessing Officer on the basis of change in facts - - RECKITT BENCKISER (I) PVT. LTD. V/s DEPUTY CIT -  26 ITCD Online 086 (ITAT-KOLKATA)