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2022 (6) TMI 656 - AT - Income TaxTP Adjustment - adjustment made on account of interest of loan on the amount advanced by the assessee to its AE - HELD THAT:- We find that identical issue arose in Revenue’s appeal for A.Y. 2011-12, 2013-14 & 2014-15. The Co-ordinate Bench of Tribunal after noting the fact that identical issue arose in assessee’s own case in earlier years and the Tribunal in A.Y. 2008-09 & 2009-10 [2022 (5) TMI 819 - ITAT DELHI] has decided the issue in favour of the assessee. The Co-ordinate Bench of Tribunal thereafter upheld the findings of CIT(A) and dismissed the appeal of the Revenue. Before us, Revenue has not placed any material on record to demonstrate that the facts in the case in the year under consideration and that of earlier years are different and distinguishable and further no material has been placed by the Revenue to demonstrate that the decision rendered by the Tribunal in assessee’s own case for earlier years has been stayed/ set aside/ overruled by higher judicial forum. In such a situation, we find no reason to interfere with the order of CIT(A). Thus grounds of the Revenue are dismissed.
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