₹2.81 C TP Addition Deleted as CIT(A) Rightly Accepted PSM Based on Consistency with Earlier Year

DCIT Vs Indianic Infotech Limited (ITAT Ahmedabad) PSM Accepted on Consistency; All Key Comparables Rejected—TNMM Fails; Entire TP Adjustment of ₹2.81 Cr Deleted Revenue’s Appeal Dismissed The Department filed appeal against the CIT(A)-11, Ahmedabad order dated 20.07.2024 deleting the entire transfer-pricing adjustment of ₹2,81,24,107 made in the case of Indianic Infotech Ltd, a software-development & export company having international transactions with its AE. Background Assessee adopted Profit Split Method (PSM) as the MAM, which was accepted by the TPO in the immediately preced...