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On materially identical facts, the adjustment for PTSE services, IT support services and centralized support services was unsustainable because the assessee had already shown rendition of services through agreements, invoices, emails, cost allocation workings and third-party evidence, and the earlier co-ordinate Bench had rejected a nil arm's length price. No distinguishing feature was shown for the year under consideration, so the binding earlier decision had to be followed. Mere pendency of the revenue's appeal did not dilute that precedent absent any stay or reversal. The transfer pricing adjustment was therefore deleted and the appeal allowed.
On materially identical facts, the adjustment for PTSE services, IT support services and centralized support services was unsustainable because the assessee had already shown rendition of services through agreements, invoices, emails, cost allocation workings and third-party evidence, and the earlier co-ordinate Bench had rejected a nil arm's length price. No distinguishing feature was shown for the year under consideration, so the binding earlier decision had to be followed. Mere pendency of the revenue's appeal did not dilute that precedent absent any stay or reversal. The transfer pricing adjustment was therefore deleted and the appeal allowed.
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