Case Law Analysis
|Income Tax Appellate Tribunal
Transfer Pricing Stay | Prior Year HC Ruling on Identical Facts Binds Revenue, ITAT Delhi Grants Absolute Stay on Royalty & Service Fee Adjustments
ITAT Delhi ruled that where a High Court has already upheld the assessee’s transfer pricing methodology for royalty and business support service fees in a prior year, the revenue cannot re-agitate the same factual matrix. The Tribunal granted an absolute stay on recovery, reinforcing judicial consistency in transfer pricing disputes and protecting taxpayers from arbitrary reassessments.