Advance Pricing Agreement applied to earlier years, sustaining deletion of the transfer pricing adjustment and defeating the Revenue's appeal.

Transfer pricing adjustment was deleted where the assessee relied on an Advance Pricing Agreement executed for later assessment years and earlier Tribunal orders applying that arrangement to the year under consideration. The First Appellate Authority accepted that position, and the Revenue did not produce a convincing basis to disturb the finding. The adjustment deletion was therefore sustained, and the connected grounds in the Revenue's appeal became infructuous.

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Issues: Whether the transfer pricing adjustment could be deleted for the year under consideration on the basis of the Advance Pricing Agreement entered into for subsequent assessment years, and consequently whether the Revenue's appeal deserved dismissal.

Analysis: The assessee relied on the Advance Pricing Agreement executed with the CBDT for later years and on earlier Tribunal orders applying that arrangement to the year under consideration. The First Appellate Authority had accepted that position, and the Revenue did not bring any convincing basis to dislodge the finding. In these circumstances, the adjustment deleted by the First Appellate Authority was upheld, and the connected grounds of the Revenue became infructuous.

Conclusion: The deletion of the transfer pricing adjustment was sustained and the Revenue's appeal failed.

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