ITAT partially allowed the assessee's appeal, directing the AO...

ITAT partially allowed the assessee's appeal, directing the AO to delete transfer pricing adjustments related to intra-group services and sales margin based on consistent treatment across assessment years. The tribunal mandated restoration of several issues to the AO's file for re-examination, including foreign exchange loss, leave encashment disallowance, and computational errors. The key principle applied was maintaining procedural consistency across assessment years, preventing the revenue department from taking contradictory positions. The appeal was substantially allowed with directions for the AO to conduct fresh scrutiny, providing reasonable opportunity of hearing to the assessee and verifying submitted documentation before finalizing the assessment order.