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Ground relates to Transfer Pricing adjustment in relation to payment of royalty to the tune of Rs. 787,096,934/-This ground covers ground no. 5 to 7 of revenue’s appeal in ITA No. 529/Kol/2015, for A.Y. 2010-11, Ground no. 6 of revenue’s appeal in ITA No. 518/Kol/2016, for A.Y. 2011-12,Ground No.4a to4b of assessee's appeal in ITA No.625/Kol/2016 for A.Y.2011-12 and additional grounds raised by the assessee in A.Y. 2011-12 wherein the assessee stated that payment of royalty was subsumed in the entity level Transactional Net Margin Method (TNMM), analysis conducted by the assessee using combined transaction approach.

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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 - [2020] 26 ITCD Online 086 (ITAT-KOLKATA)