Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
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