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The ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A). On transfer pricing, the Tribunal followed its own decisions in the assessee's earlier assessment years, holding that no further upward adjustment was warranted in respect of the corporate guarantee fee/commission charged on guarantees provided to AEs, there being no change in facts or law. On MEIS receipts, the ITAT affirmed the CIT(A)'s treatment of such receipts as capital in nature, relying on its prior orders in the assessee's own case and aligned with SC jurisprudence, and therefore declined to interfere with the relief granted.
The ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A). On transfer pricing, the Tribunal followed its own decisions in the assessee's earlier assessment years, holding that no further upward adjustment was warranted in respect of the corporate guarantee fee/commission charged on guarantees provided to AEs, there being no change in facts or law. On MEIS receipts, the ITAT affirmed the CIT(A)'s treatment of such receipts as capital in nature, relying on its prior orders in the assessee's own case and aligned with SC jurisprudence, and therefore declined to interfere with the relief granted.
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