Held, that the arm’s length price adopted by the assessee at LIBOR plus 200 basis points had been accepted by the Tribunal in the earlier years. No distinguishing feature was pointed out by the Revenue in these two years, to take a different view. Accordingly, the view taken by the Commissioner (Appeals) is  proper. Held  that the Commissioner (Appeals) had given categorical finding that ANJ was not functionally comparable. No material was brought to contradict finding of the Commissioner (Appeals). The Commissioner (Appeals) was justified in rejecting this company. Held, that the Tribunal had been consistently upholding the yield spread approach and also splitting of differential interest in the ratio 50 : 50 between the assessee and its associated enterprises. Order of CIT(A) is affirmed. Held that since, the Tribunal consistently upheld the practice of adopting internal comparable uncontrolled price in respect of transaction of sale of power to non-eligible undertaking and since the Commissioner (Appeals) had followed the order passed by the Tribunal in the earlier years, which had been upheld by the High Court in one of the years, the order passed by the Commissioner (Appeals) on this issue was to be upheld. (AY.2017-18, 2018-19)