CIT v. GE India Technology Centre (P) Ltd. (2021) 278 Taxman 261 (Karn.)(HC)

S. 92C : Transfer pricing-Arm’s length price-Interest rate-Accepted earlier year as well as subsequent assessment years-Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year.

Dismissing the appeal of the revenue the Court held that Reserve Bank of India had given approval with regard to said rate of interest adopted by assessee which was a relevant factor to determine rate of interest.  TPO had accepted such rate of interest adopted by assessee for assessment years 2002-03 to 2008-09 except for relevant assessment year 2006-07.Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year.  (AY 2006-07)