https://www.taxtmi.com/caselaws?id=772933 The ITAT Mumbai held that the assessee's benchmarking of international transactions relating to processing fees from guarantees using TNMM as the most appropriate method was correct. The tribunal relied on its coordinate bench decision in the assessee's own case and noted that identical transactions were previously accepted by the TPO until AY 2012-13. Applying the consistency principle established in Radhasoami Satsang, the tribunal directed deletion of the transfer pricing adjustment made by the TPO, as there was no change in facts and circumstances from earlier years. The assessee's appeal was allowed. en-us Wed, 28 May 2025 00:00:00 +0530 Mon, 16 Jun 2025 08:38:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772933 The ITAT Mumbai held that the assessee's benchmarking of international transactions relating to processing fees from guarantees using TNMM as the most appropriate method was correct. The tribunal relied on its coordinate bench decision in the assessee's own case and noted that identical transactions were previously accepted by the TPO until AY 2012-13. Applying the consistency principle established in Radhasoami Satsang, the tribunal directed deletion of the transfer pricing adjustment made by the TPO, as there was no change in facts and circumstances from earlier years. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 28 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772933