PCIT v. Wrigley India Pvt. Ltd. (2023)459 ITR 2 /156 taxmann.com 245 (Delhi)(HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Advertising, marketing and promotion expenditure-Principle of consistency applies-Order of Tribunal is affirmed. [S. 92]

Held, dismissing the appeal, that the order of the Tribunal with regard to the assessee for the assessment years 2007-08 to 2009-10, indicated that applications preferred by the Revenue had been dismissed and the Revenue had not taken any legal remedy. Given this and the fact that there had been no change in the circumstances concerning the assessee, which had been noted by the Tribunal, the principle of consistency would apply. Order of Tribunal is affirmed. (AY.2010-11)