https://www.taxtmi.com/caselaws?id=310446 ITAT Ahmedabad allowed assessee's appeal regarding transfer pricing adjustment on interest payments to associated enterprise. Assessee paid interest at LIBOR + 3% to AE, which TPO accepted in assessment year 2006-07 but later benchmarked at LIBOR + 0.77% for subsequent year. Tribunal applied rule of consistency, holding that absent changed facts and circumstances, TPO cannot take different view from previously accepted rate. Since no factual changes occurred between assessment years, no disallowance of interest expenses was warranted. Tribunal clarified decision should not be used as precedent in other cases as ruling based solely on consistency principle. en-us Mon, 04 Mar 2019 00:00:00 +0530 Thu, 26 Oct 2023 07:43:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310446 ITAT Ahmedabad allowed assessee's appeal regarding transfer pricing adjustment on interest payments to associated enterprise. Assessee paid interest at LIBOR + 3% to AE, which TPO accepted in assessment year 2006-07 but later benchmarked at LIBOR + 0.77% for subsequent year. Tribunal applied rule of consistency, holding that absent changed facts and circumstances, TPO cannot take different view from previously accepted rate. Since no factual changes occurred between assessment years, no disallowance of interest expenses was warranted. Tribunal clarified decision should not be used as precedent in other cases as ruling based solely on consistency principle. Case-Laws Income Tax Mon, 04 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310446