https://www.taxtmi.com/caselaws?id=307472 The ITAT Pune allowed the appeal for statistical purposes, remitting the case back to the Commissioner of Income Tax (Appeals) for re-evaluation based on the APA terms. The decision emphasized the importance of consistency in transfer pricing treatment and the potential application of APA terms to non-APA years, subject to transaction similarity. en-us Fri, 19 Jan 2018 00:00:00 +0530 Sun, 16 Apr 2023 17:07:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307472 The ITAT Pune allowed the appeal for statistical purposes, remitting the case back to the Commissioner of Income Tax (Appeals) for re-evaluation based on the APA terms. The decision emphasized the importance of consistency in transfer pricing treatment and the potential application of APA terms to non-APA years, subject to transaction similarity. Case-Laws Income Tax Fri, 19 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307472