Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (9) TMI 1750 - AT - Income TaxAMP expenditure incurred as treated and categorized as an international transactions u/s 92B - Held that:- The judicial discipline also demands that, in case there is no change in the facts and circumstances of the case, the issue decided by the coordinate bench in assessee’s own case for earlier years on identical facts and circumstances, should be followed by the coordinate bench while deciding the similar issue for later years. Therefore, respectfully following the decision of the coordinate bench in assessee’s own case, we also hold that the transfer pricing adjustment made by the ld TPO on account of arm’s length price of alleged international transaction of AMP expenditure is unsustainable. - Decided in favour of assessee.
|