The issue in dispute was the Arm’s Length price with respect to payment of management fees for availing intra group services. The said issue was covered by the ITAT decisions in its own cases for the previous years. Accordingly, the ITAT followed the principles of consistency and applied the doctrine of judicial discipline in the present case. There was no material alteration in the facts as compared to the previous years. Following coordinate Bench decision, the ITAT allowed the appeal of the assessee and transfer pricing adjustment was deleted. (AY. 2012-13)
Metalsa India (P) Ltd. v. Dy. CIT (2022) 209 DTR 1 /215 TTJ 137 (Delhi)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Management fees-Followed order of earlier year-Addition was deleted [S. 92CA]