TP Adjustment Rejected as Revenue Departed from Consistent Past Practice: Karnataka HC

CIT Vs GE India Technology Centre Pvt. Ltd. (Karnataka High Court) The Karnataka High Court considered the Revenue’s appeal under Section 260A of the Income-tax Act, 1961 for Assessment Year 2006-07. The appeal raised three principal issues relating to the computation of deduction under Section 10A, the transfer pricing adjustment concerning interest on external commercial borrowings, and the determination of the arm’s length price for such borrowings. Background of the case: The assessee, engaged in research and development in material sciences, process technology, and related software de...