Summary
- The ITAT Delhi has remanded a ₹50.20-lakh transfer pricing adjustment for Honda R&D (India) Private Limited, emphasizing the need for consistent treatment across assessment years.
- The Tribunal noted that the TPO accepted identical transfer pricing issues for AY 2021-22, which should influence the decision for AY 2020-21.
- This ruling underscores the principle of consistency in tax assessments, requiring the Department to explain any contradictions in similar cases.
- The outcome could reshape future transfer pricing disputes, as favorable decisions in one year may significantly impact related assessments.
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