U.L. India Pvt. Ltd. v. Dy. CIT (2022)96 ITR 191 (Bang)(Trib)

S. 92C : Transfer pricing-Arm’s length price-Change in method of revenue recognition deferring recognition of revenue-Assessing Officer to give consequential relief in year in which revenue deferred was offered to tax. [S. 145]

The Tribunal held that with regard to the change in the method of revenue recognition deferring the recognition of revenue, the Assessing Officer should give consequential relief in the year in which the revenue deferred was offered to tax to ensure that there was no double taxation. (AY. 2010-11, 2011-12)