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.
Want to Read the Complete Judgment?
You have read the free case summary. Unlock the full judgment, the detailed judicial reasoning and the downloadable PDF, along with every other premium judgment on TaxGuru.
Already subscribed? Log in
One subscription covers the entire premium judgment library, not just this case.
