Honda R And D (India) Private Limited Vs DCIT (ITAT Delhi)
When TPO Accepts The Same TP Study Next Year, He Cannot Speak A Different Language For The Earlier Year—₹50.20-Lakh Adjustment Remanded For Consistent Relief U/s 92CA
Background
Honda R&D (India) Private Limited challenged the final assessment order dated 26 July 2024 passed by the AO-NFAC u/s 143(3) r.w.s. 144C(13) & 144B.
Following the directions issued by the DRP on 26 June 2024, the AO made a transfer-pricing adjustment of ₹50,19,930. The assessee approached the Tribunal with twelve grounds challenging the adjustment both on merits & on legal grounds.
The Tribunal heard the appeal in detail & concluded the hearing on 10 August 2026. However, a significant development occurred immediately thereafter.
Post-Hearing Development
By a letter dated 17 August 2026, the assessee brought to the Tribunal’s notice an order dated 14 August 2026 passed by the TPO for the immediately succeeding AY 2021-22.
The assessee submitted that the transfer-pricing issue examined for AY 2021-22 was identical to the controversy pending before the Tribunal for AY 2020-21. In the subsequent year’s proceedings, the TPO had examined the additional evidence, transfer-pricing documentation & economic analysis furnished by the assessee and had granted complete relief.
