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The High Court held that the NOIDA-II unit was entitled to deduction u/s 10A of the Income Tax Act for its profits and gains derived from the NOIDA-I unit. The court applied the principles of consistency and certainty in taxation, stating that once the Revenue accepts the findings in favor of the assessee in the initial year(s), it cannot be re-agitated on the same set of facts in subsequent years without any change in circumstances or new facts. Regarding transfer pricing adjustment, the court ruled that the Transactional Net Margin Method (TNMM) should be applied at the enterprise level, considering the singularity of the agreement between the associated enterprises and the interlacing of funds and unity of management. The court decided in favor of the assessee on the issue of crystallization and accrual of liability towards payroll taxes, holding that the liability arose when the reconciliation was conducted at the end of the Australian tax year.
The High Court held that the NOIDA-II unit was entitled to deduction u/s 10A of the Income Tax Act for its profits and gains derived from the NOIDA-I unit. The court applied the principles of consistency and certainty in taxation, stating that once the Revenue accepts the findings in favor of the assessee in the initial year(s), it cannot be re-agitated on the same set of facts in subsequent years without any change in circumstances or new facts. Regarding transfer pricing adjustment, the court ruled that the Transactional Net Margin Method (TNMM) should be applied at the enterprise level, considering the singularity of the agreement between the associated enterprises and the interlacing of funds and unity of management. The court decided in favor of the assessee on the issue of crystallization and accrual of liability towards payroll taxes, holding that the liability arose when the reconciliation was conducted at the end of the Australian tax year.
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