Transfer Pricing – Principal of consistency need not be followed despite no change in assessee’s operating model/activity

 ITAT DELHI BENCH ‘G’ Sumitomo Corporation India (P.) Ltd. versus Deputy Commissioner of Income-tax IT Appeal No. 5095 (Delhi) OF 2011 [ASSESSMENT YEAR 2007-08] JANUARY  31, 2013 ORDER Shamim Yahya, Accountant Member This appeal by the Assessee is directed against the order of the Assessing Officer passed u/s. 143(3) read with section 144C of the I.T. Act for assessment year 2007-08. 2. The grounds raised read as under:- 1. That the learned Deputy Commissioner of Income Tax, Circle 9(1), New Delhi has erred both on facts and, in law in determining income of the A...