Principle of consistency applies if facts and circumstances are same

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 g

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