Principle of consistency applies if facts and circumstances are same

Brief of the Case ITAT Lucknow held In the case of JCIT vs. M/s Super House Leather Ltd. that following the judgment of Bombay High Court in the case of Godrej And Boyce Mfg. Co. Ltd. vs. DCIT [2010] 328 ITR 81 (Bom), it is clear that Rule 8D is prospective and therefore, applicable from assessment year 2008-09 and afterwards. Therefore, Rule 8D is not applicable in the present year. In the matter of transfer pricing adjustment, no reasons have been given by the present TPO to reject the method of Cost Plus basis adopted by the assessee and accepted by the Department in earlier year(s). Althou...